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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Operation of S10A for Non-UK Domiciled individuals - No claim to Remittance Basis - year of departure 2013-14 or later

If no election for the remittance basis is made for the year of return, TCGA92\S10A applies in the normal way and any gains of a period of temporary non-residence are chargeable in the period of return.


Mr A a non-UK domiciled individual leaves the UK in 2016-17 and becomes non-resident from 6/4/17.

Whilst living abroad and in 2019-20 he realises a gain on an asset that has been held for many years. He then returns to the UK on 1 September in 2020-21. (2020-21 is a split year and the UK part starts on 1/9/20).

The gain made in year 2019-20 is a gain that has arisen in a period of temporary non-residence and is regarded under S10A as a chargeable gain of the period of return.

As there is no election for the remittance basis for 2020-21 (the year in which the period of return falls) the gain is assessable for the period of return, this will be in 2020-21.

S10A operates in the same way for both UK domiciled and non-domiciled individuals to exclude gains from its scope where the asset disposed of was acquired during a period of temporary non-residence. Further information is given in CG26590.