CG73836 - Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Gifts on which inheritance tax is chargeable
TCGA92/S260 is concerned with cases where gifts are exempt or potentially exempt from inheritance tax (see CG67040). This is amended, so that where assets involved in a non-resident CGT disposal are disposed of as a gift from a non-UK resident to a UK resident, non-resident CGT gains may be included as held-over gains under this provision.