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Background

Historically, only UK resident individuals and entities, together with temporary non-UK resident individuals and those operating via a UK permanent establishment, branch or agency, were subject to UK capital gains tax (CGT), whilst non-UK residents were not. However, this was widened from 6 April 2013 to include disposals of UK dwellings owned by non-resident companies, partnerships and collective investment schemes where the dwelling was subject to the annual tax on enveloped dwellings (ATED) charge, which was subsequently repealed in April 2019 due to the introduction of the regime discussed below. For more on the ATED charge and the ATED-related CGT charge, see the Overview of the ATED regime guidance note.

From 6 April 2015, the CGT regime was extended to non-UK residents disposing of UK residential property. This was known as the non-resident capital gains tax (NRCGT) regime. The NRCGT regime was rewritten and extended to cover both non-residential UK property and indirect disposals of UK property with effect from 6 April 2019, meaning all disposals of interests in UK land