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HMRC internal manual

Capital Gains Manual

Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015: Companies: Special rules: Non-resident CGT disposals: roll-over relief

TCGA92/S159A modifies the provisions on roll-over relief in TCGA92/S152.  It provides that relief does not apply to a person chargeable to non-resident CGT on a gain relating to the original assets, unless the replacement assets represent a UK residential property interest within the charge to non-resident CGT at the time they are acquired (see CG60250).