Taxation of Chargeable Gains Act 1992 section 159A

Disposals of interests in UK land by non-residents: roll-over relief

Section 159A restricts the availability of roll-over relief for non-residents who dispose of interests in UK land, ensuring that the relief only applies where the replacement assets are also interests in UK land.

• The section applies where a non-resident disposes of interests in UK land and the resulting chargeable gain falls within the UK tax charge specifically because of the non-resident land disposal rules.
• Roll-over relief under section 152 is only available if the replacement assets acquired are also interests in UK land — reinvestment into other classes of business asset will not qualify.
• References to disposing of old assets or acquiring new assets include disposing of or acquiring an interest in those assets, and acquiring new assets includes entering into an unconditional contract for their purchase.
• "Interest in UK land" takes its meaning from section 1C of the Act, and the terms "old assets" and "new assets" carry the same meaning as in section 152.