Indirect disposals of UK land bring non-residents into CGT

Changes to the capital gains tax (CGT) rules on sales of land mean that non-UK residents will be captured by the CGT regime for the first time from April 2019, raising complex tax compliance issues, explains Stephanie Webber CTA, tax writer at Croner-i

As well as bringing all disposals of UK land by non-UK residents within the scope of either capital gains tax or, for companies, corporation tax, Finance Bill 2018-19 (now expected to receive Royal assent on 12 February) also targets indirect disposals, where the disposal by the non-resident is of an entity that holds UK land. 

The plans were first announced at Autumn Budget 2017, stating that from April 2019, tax would be charged on gains made by non-residents on the disposal of all types of UK immovable property, extending existing rules that apply only to residential property.

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