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HMRC internal manual

Capital Gains Manual

Non-Resident Capital Gains Tax (NRCGT) - Disposals from 6 April 2015 to 5 April 2019: Introduction: Non-resident CGT - when and why it was introduced

It was announced in 2014 that the government planned to extend the scope of tax on chargeable gains to disposals of residential property by non-residents, including disposals by certain non-resident companies.

Following consultation the new rules were enacted in FA 2015, and took effect from April 2015.  The  charge is sometimes referred to as “NRCGT”, which was the term used extensively in the statute itself.


Among the key aims underlying the new tax were the following -

  • to impose a charge on the gains of non-residents from disposal of interests in residential property, essentially dwellings used by households, but not communal or institutional type accommodation;
  • in the case of non-resident corporate entities disposing of such property, to impose the charge on closely-held companies, but to exempt companies that meet a genuine diversity of ownership test, and widely marketed investment companies;
  • to apply special arrangements to collect the tax due, so that the non-resident person making the disposal was required to pay tax on account directly to HMRC at or close to the time of disposal;
  • to operate the new non-resident CGT charge alongside the existing ATED-related CGT charged by TCGA92/S2B (see CG73600+), but on the basis that where a disposal could be liable under both heads, ATED-related CGT would be charged in priority over non-resident CGT.

From 6 April 2019 the scope of the charge on non-residents was extended to include all interests in UK land and indirect disposals. Guidance on the changes is at CG73920+.