Taxes Management Act 1970 section 12ZD

NRCGT returns: grant and exercise of options

Section 12ZD sets out special rules for Non-Resident Capital Gains Tax (NRCGT) returns where a disposal of UK property involves the grant or exercise of an option, ensuring the correct reporting obligations and deadlines apply.

• When an option over UK property is granted, the person granting the option must file an NRCGT return for that disposal, with the reporting deadline running from the date the option is granted.
• When an option is exercised, the exercise is treated as a separate disposal for NRCGT return purposes, and a further return may be required at that point.
• If the grant of the option has already been reported, the person may need to amend or submit a new return when the option is subsequently exercised, reflecting any changes in the gain or loss calculation.
• These rules ensure that both the grant and the exercise of an option are properly captured for NRCGT reporting, even though they are distinct events that may occur at different times.

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