I have a client who de-enveloped the UK property, i.e. liquidated the non resident company and distributed the property in her name. This was done to avoid ATED charges, and she is also taking up residence in the UK property, so also to do with PPR relief.
There was no gain or loss. The NRCGT return was filled late and there are penalties of about £1400.
I have appealed in August 2016 on reasonable excuse. HMRC returned the appeal to me saying the tax payer does not have a national insurance number so can’t process. Rewrote to them saying is a Non resident company with no UTR as it did not haev UK source income. It only had ATED reference and CGT case reference when NRGCT was filed. (all references were provided initially). They asked me to resend the appeal, which i sent in November 2016. I have heard nothing from them yet.
I just saw this no gain/no loss relief for penalties at Section 12ZBA – Elective NRCGT return, Would the above situation fall under no gain/no loss situation?
Any help will be highly appreciated.
Many thanks

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