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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: Gifts to non-residents

TCGA92/S166 is concerned with gift of business asset hold-over relief (see CG66912).  Changes linked with new TCGA92/S167A have the effect that relief is denied in cases where a gift of UK residential property interests chargeable to non-resident CGT is to a non-UK resident.