A good number of expatriates return, sooner or later, to live again in the UK. As they plan their return, some may find their current country of residence allows them to sell or otherwise deal in assets free of local taxation.

There is the obvious opportunity, if they sell assets that are pregnant with gain before taking up UK residence again, for gains on sale to be free of tax altogether.

The UK tax position has of course changed somewhat since the introduction, in 2015, of the charge to capital gains tax (CGT) for non-residents disposing of UK residential property.