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HMRC internal manual

Capital Gains Manual

Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015: Interaction between Non-Resident CGT and ATED-related CGT: Interest under contract for 'off-plan' purchase

Sch 4ZZB/para 21 applies where a non-resident CGT disposal of a UK residential property interest relates to disposal of an interest under a contract for off-plan purchase.  This is a contract to acquire land that consists of, or includes, a building that is to be constructed as a dwelling.  The land that is the subject of the contract is treated as consisting of or including a dwelling throughout the person’s period of ownership of the interest.  Consequently, the provisions of Sch 4ZZB/Part 4 (cases involving ATED-related disposals) apply in such cases.


See also CG73758 on disposals of interest in UK land under contracts for off-plan purchase