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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: Wasting assets for purposes of Sch 4ZZB

Sch 4ZZB/Para 24 explains how wasting assets (as defined in TCGA92/Chapter 2 Part 2) should be taken into account when calculating gains and losses on certain disposals, including relevant high value disposals.

 

It addresses the question of whether the interest which is the subject of the disposal is a wasting asset, when computing notional gains or losses accruing to a person on certain disposals.  The assumptions that the interest was acquired on 5 April 2015 or 5 April 2016 are to be ignored in determining that question.

 

This applies to computations of the following -

  • the notional post-April 2015 gain or loss accruing to a person on a non-resident CGT disposal in accordance with paragraph 5(2)(a),
  • the notional post-April 2015 gain or loss accruing to a person on a relevant high value disposal in accordance with paragraph 13(3),
  • the notional post-April 2016 gain or loss accruing to a person on a relevant high value disposal in accordance with paragraph 15(5), or
  • the notional pre-April 2016 gain or loss accruing to a person on a disposal in accordance with paragraph 15(7).