CG73877 - Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Interaction between Non-Resident CGT and ATED-related CGT: Pre-April 2015 assets computations, examples
Asset held on 5 April 2013 and April 2015, and always within the scope of ATED
Asset held on 5 April 2013 and 5 April 2015, and only within the scope of ATED from 1 April 2015
Asset held on 5 April 2015, and always within the scope of ATED
These examples follow on from examples in the ATED-related CGT guidance. They show how to calculate the NRCGT gain or loss on those disposals after calculating the ATED-related gain or loss.
1. Asset held on 5 April 2013 and April 2015, and always within the scope of ATED
Shows how to calculate the NRCGT gain on example 1 at CG73643
Basic information:
Interest acquired April 2006 for £3,000,000 and disposed of 5 April 2016 for £6,000,000.
The property had a value of £5,600,000 at 5 April 2015.
Total number of days chargeable to ATED (say) 700
Pre April 2015 ATED chargeable days 365
Post April 2015 ATED chargeable days 335
Total days 6 April 2015 to disposal 365
Estimated Indexation factor April 2015 to April 2016 0.035
Step 1
Determine the amount of the post-April 2015 gain or loss
Disposal proceeds £6,000,000
Market value at 5 April 2015 £5,600,000
Indexation allowance £196,000
Notional post April 2015 gain £204,000
Step 2
Determine the “special fraction” of the notional post-April 2015 gain or loss
SD = 30
TD = 365
SD/TD x Notional post April 2015 gain = £16,767
NRCGT gain £16,767
2. Asset held on 5 April 2013 and 5 April 2015, and only within the scope of ATED from 1 April 2015
Shows how to calculate the NRCGT gain on example 2 at CG73628
Basic information:
Residential property acquired April 2010 for £800,000 and disposed of on 7 April 2016 for £1,400,000.
The property had a value of £1,200,000 at 5 April 2015.
Estimated Indexation factor April 2010 to April 2016 0.11
Total number of days chargeable to ATED (assumed) 200
Total days 6 April 2015 to disposal 365
Step 1
Determine the amount of the post-April 2015 gain or loss
Disposal proceeds £1,400,000
Market value at 5 April 2015 £1,200,000
Indexation allowance £132,000
Notional post-April 2015 gain £68,000
Step 2
Determine the “special fraction” of the notional post-April 2015 gain or loss
SD = 165
TD = 365
SD/TD x Notional post April 2015 gain = £30,740
NRCGT gain £30,740
3. Asset held on 5 April 2015, and always within the scope of ATED
Shows how to calculate the NRCGT gain on example 2 at CG73643
Basic information:
Residential property acquired April 2014 for £4,000,000 and disposed of April 2018 for £6,000,000.
Estimated Indexation factor April 2015 to April 2018 say 0.2
Total number of days chargeable to ATED 730
Total days April 2015 to April 2018 1,095
Market value at 5 April 2015 is £4,250,000
Step 1
Determine the amount of the post-April 2015 gain or loss
Disposal proceeds £6,000,000
Market value at 5 April 2015 £4,250,000
Indexation allowance £850,000
Notional post-April 2015 gain £900,000
If all ATED days fall after April 2015
Step 2
Determine the “special fraction” of the notional post-April 2015 gain or loss
SD = 365
TD = 1,095
SD/TD x Notional post April 2015 gain = £300,000
NRCGT gain £300,000
If all ATED days fall at the beginning of the period
Step 2
Determine the “special fraction” of the notional post-April 2015 gain or loss
SD = 730
TD = 1,095
SD/TD x Notional post April 2015 gain = £600,000
NRCGT gain £600,000
See CG73894 for how to calculate the gain or loss that is neither ATED-related nor an NRCGT gain or loss.