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HMRC internal manual

Capital Gains Manual

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HM Revenue & Customs
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Arrival in and departure from UK: temporary non-residence: gains or losses excluded from TCGA92/S10A - year of departure 2013-14 or later

Where assets have been acquired by an individual during a residence period when they do not have sole UK residence, and that residence period falls within a period of temporary non-residence, then any gains realised on those assets in the period of temporary non residence will in general be excluded from the scope of TCGA92/S10A and hence from the charge under TCGA92/S2, see CG26600. Similarly losses accruing in such circumstances will not be allowable.

This exclusion from the scope of TCGA92/S10A will not apply to assets held in a non-resident trust or closely controlled non resident company.

There are further exceptions to the general rule. Where an asset held before departure stands at a gain, and that gain is rolled-over or its accrual is otherwise deferred until another asset is disposed of during the period of absence, then TCGA92/S10A contains provisions which prevent such gains escaping tax. See CG26610 and CG26630.