Taxation of Chargeable Gains Act 1992 section 14E

Further provision about use of NRCGT losses

Section 14E provides additional rules governing how non-resident capital gains tax (NRCGT) losses may be used, including restrictions on their availability and the circumstances in which they can be set against other gains.

• NRCGT losses are ring-fenced and can generally only be set against NRCGT gains, not against wider chargeable gains.
• There are specific ordering rules that determine how NRCGT losses are applied when a person has both NRCGT gains and other chargeable gains in the same tax year.
• The provisions were amended by Finance Act 2019 (Schedule 1, paragraph 2), reflecting changes to the taxation of non-residents disposing of UK property.
• These rules ensure that losses arising from the NRCGT regime are not used to shelter gains that fall outside that regime.

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