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