Taxation of Chargeable Gains Act 1992 section 14B

Meaning of "non-resident CGT disposal"

Section 14B defines what constitutes a "non-resident CGT disposal" for the purposes of capital gains tax, covering disposals of UK land, property-rich assets, and certain indirect interests by non-UK residents.

• A non-resident CGT disposal includes any disposal of an interest in UK land by a non-UK resident person, whether the disposal is direct or indirect.
• Disposals of assets that derive at least 75% of their value from UK land (known as "property-rich" assets) can also qualify as non-resident CGT disposals, subject to certain conditions.
• The definition extends to disposals by non-resident companies, trusts, and partnerships, as well as individuals, ensuring broad coverage of UK property-related gains made by those outside the UK tax net.
• The rules were significantly expanded by Finance Act 2019 to capture indirect disposals of UK land, not just direct disposals, bringing the UK into line with international practice on taxing property gains.

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