TCGA 1992, s. 1(1) is the basic charging provision in respect of CGT. It provides:

‘Tax shall be charged in accordance with this Act in respect of capital gains, that is to say chargeable gains computed in accordance with this Act and accruing to a person on the disposal of assets.’

Section 2(1) then defines a person who is chargeable to CGT. It provides that:

‘Subject to any exceptions provided by this Act, and without prejudice to sections 10 and 276, a person shall be chargeable to capital gains tax in respect of chargeable gains accruing to him in a year of assessment if the residence condition is met.'487

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