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HMRC internal manual

Capital Gains Manual

Location of assets: importance for reliefs

A relief that may be dependent on the location of assets is roll-over relief for persons who are neither resident nor ordinarily resident* both at the date of disposal of the old assets and at the date of acquisition of the new assets. Only assets which are liable to a charge

  • under TCGA92/S10 (assets situated in the UK and used in or for the purposes of a branch or agency of a trade, profession or vocation carried on by a non-resident person other than a company), or
  • under TCGA92/S10B (assets situated in the UK and used in or for the purposes of a permanent establishment of a trade carried on by a non-resident company)

can qualify for roll-over relief in these circumstances, TCGA92/S159, see CG61350+.

  • For 2013/14 and subsequent years ordinary residence does not need to be considered.