CG67031 - Relief for Gifts Subject to Inheritance Tax: The Donor
Under TCGA92/S260(1)(a), the donor can either be an individual or the trustees of a settlement. There is no requirement that the donor is UK resident, hence non-residents within the charge to CGT, such as those disposing of interests in UK land or assets (wherever situated) that derive at least 75% of their value from UK land where the person has a substantial indirect interest in that land, can access the relief.
The relief is also available for trustees of non-resident settlements, where the chargeable gain would, or might otherwise be, charged on UK residents.