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HMRC internal manual

Capital Gains Manual

Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Gifts of UK residential property interests to non-residents

TCGA92/S261ZA is concerned with cases where assets are disposed of as a gift from a UK resident to a non-UK resident in the circumstances envisaged by TCGA92/S260, and the disposal relates to a UK residential property interest.  It provides that hold-over relief is not denied where the asset is chargeable to non-resident CGT in the hands of the person to whom the asset is transferred.  The full amount of the held-over gain accrues as a chargeable non-resident CGT gain for the transferee when they subsequent dispose of the asset.