In an attempt to level the playing field for disposals of property by both UK-residents and non-residents, legislation had been introduced effective from 6 April 2015 subjecting non-residents to a non-resident capital gains tax (NRCGT) charge when disposing of UK residential property. FA 2019 extended the scope of the charge so that it also now includes indirectly held property and commercial property.

NRCGT is chargeable on the disposal of UK property by:

non-resident individuals;

personal representatives of a non-resident who has died;

non-resident trustees;

non-resident companies (including deemed companies) and funds;

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