CG12411 - Location of assets: importance for reliefs

A relief that may be dependent on the location of assets is roll-over relief for persons who are neither resident nor ordinarily resident* both at the date of disposal of the old assets and at the date of acquisition of the new assets. Only assets which are liable to a charge

• under TCGA92/S10** (assets situated in the UK and used in or for the purposes of a branch or agency of a trade, profession or vocation carried on by a non-resident person other than a company), or
• under TCGA92/S10B** (assets situated in the UK and used in or for the purposes of a permanent establishment of a trade carried on by a non-resident company)
• under TCGA92/S14B (from 6 April 2015 to 5 April 2019 - interests in UK residential property - see CG73700 onwards) or TCGA92/S1A(3) (from 6 April 2019 - direct or indirect disposals of interests in UK real property - see CG73920 onwards)

can qualify for roll-over relief in these circumstances, TCGA92/S159, see CG61350 onwards.

* For 2013/14 and subsequent years ordinary residence does not need to be considered.

**These provisions were re-written for disposals from 6 April 2019 - see CG10150.