CG73831 - Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Gifts of UK residential property interests to non-residents
TCGA92/S167A modifies the rules in TCGA92/S165 on relief for gifts of business assets. It is concerned with cases where assets are disposed of as a gift from a UK resident to a non-UK resident, and the disposal relates to a UK residential property interest. It provides that hold-over relief is not denied where the asset is chargeable to non-resident CGT in the hands of the person to whom the asset is transferred. The full amount of the held-over gain accrues as a chargeable non-resident CGT gain for that person at the point when they subsequently dispose of it.