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HMRC internal manual

Capital Gains Manual

Migration and exit charges: recovery: held over gains: change of residence

Where there has been a claim to hold-over a gain on a gift under

  • FA80/S79, as extended by FA81/S78, and FA82/S82


  • CGTA79/S147A


  • TCGA92/S165 and SCH7


  • TCGA92/S260

and the individual or trustee who is the transferee becomes neither resident nor ordinarily resident in the United Kingdom, there are provisions for the whole or part of the held-over gain to be assessed on the transferee, see CG67270+. Such a charge should be considered immediately non-resident status is known or suspected.

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