Taxation of Chargeable Gains Act 1992 section 188F

Companies becoming eligible to join an NRCGT group

Section 188F dealt with the rules that applied when a company became eligible to join a non-resident capital gains tax (NRCGT) group, as part of the framework for taxing gains on UK property disposals by non-UK resident companies.

• Section 188F was part of a suite of provisions (sections 188A–188K) introduced by the Finance Act 2015, which established rules for grouping non-resident companies for the purposes of the non-resident capital gains tax regime.
• These provisions applied to disposals of UK residential property interests made on or after 6 April 2015 by non-UK resident persons.
• The entire set of NRCGT group provisions, including section 188F, was repealed by the Finance Act 2019 as part of a broader restructuring of how non-residents are taxed on UK property gains.
• The repeal took effect for capital gains tax purposes from the 2019–20 tax year onwards, and for corporation tax purposes for accounting periods beginning on or after 6 April 2019.

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