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HMRC internal manual

Capital Gains Manual

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HM Revenue & Customs
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Capital Gains manual: individuals: effects of residence, ordinary residence and domicile: arrival in and departure from the UK: 2013-14 and later years - individuals becoming or ceasing to be resident in the UK - split years

Although an individuals residence status will only change at the start or following the end of a tax year split year treatment may apply see CG10978.

When a year is regarded as a split year it is divided into a UK part of a split year and an overseas part of a split year. Normally this will mean that the individual is not chargeable to capital gains tax in respect of any chargeable gains accruing to him or her in the overseas part of the year.

This normal rule may not apply where:

  • The individual would have been chargeable to CGT under TCGA1992/S10 (non-UK resident trading through a branch or agency) had the individual been not resident in the UK for the year see CG25515
  • TCGA1992/S10A (temporary non-residence periods) applies see CG26500+
  • Gains attributed under TCGA92/S86 that arise in a year are treated as falling within the UK part of a split year. See CG38400+.
  • The disposal is of an interest in residential property and the individual is liable to NRCGT. See CG73700+.