Taxation of Chargeable Gains Act 1992 section 188J

The representative company of an NRCGT group

Section 188J established the concept of a representative company within a non-resident capital gains tax (NRCGT) group, defining how such a company was identified and its role in relation to group disposals of UK residential property. This section has now been omitted.

• Section 188J was part of a suite of provisions (sections 188A–188K) introduced by Finance Act 2015 to impose capital gains tax on non-UK resident persons disposing of UK residential property from 6 April 2015 onwards.
• The section defined how a representative company was identified within a group of non-resident companies for the purposes of the NRCGT regime, enabling HMRC to deal with a single entity on behalf of the group.
• Sections 188A–188K were omitted in their entirety by Finance Act 2019, section 13 and Schedule 1, paragraph 68, as part of a broader reform extending the charge on non-residents to all UK land disposals.
• The omission 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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