Taxation of Chargeable Gains Act 1992 Schedule BA1 paragraph 1

Meaning of "disposal of a non-UK residential property interest"

Schedule BA1 paragraph 1 defines what constitutes a disposal of a non-UK residential property interest for capital gains tax purposes.

• A disposal of a non-UK residential property interest occurs when a person disposes of an interest in land situated outside the United Kingdom, and the land consists of or includes a dwelling on the day of disposal.
• The definition also covers situations where the land has consisted of or included a dwelling at any time during the ownership period, even if no dwelling exists on the disposal date.
• The concept extends to disposals of interests in entities that derive at least 75% of their value from non-UK residential property, such as shares in property-rich companies.
• This provision was introduced by Finance Act 2019 as part of the extension of UK capital gains tax to non-UK residents disposing of interests in non-UK residential property.