The regime for taxing non-residents’ gains on the disposal of UK real estate has been settled by Finance Act 2019 (FA 2019). The road to taxing such gains has been a relatively long and winding one. It started in earnest from April 2013 with the charge on companies owning high-value residential property – the annual tax on enveloped dwellings related capital gains tax (ATED-related CGT); and then from April 2015, the charge on a wider range of non-resident persons in respect of residential property gains generally (the acronym here being NRCGT).

This article looks specifically at the current treatment, per FA 2019, of UK real estate gains of offshore collective investment vehicles (CIVs), and the related impact for prospective investors in such funds. Such vehicles are able to benefit from exemption from charge if they meet certain conditions.