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Development of the law

Prior to April 2013, non-resident companies were typically not within the scope of UK corporation tax on chargeable gains, save in respect of capital assets which were used as part of a UK permanent establishment. This offered a particular incentive to non-resident companies investing in UK land. However, from April 2013, there has been a gradual erosion of this tax benefit. See the Direct disposals of interests in UK land by non-residents guidance note for a summary of the changes up to 6 April 2019.

From 6 April 2019, all disposals of interests in UK land by non-residents are within scope of either the CGT or corporate chargeable gains regime. Any overseas entity owning or leasing UK property should register on the Register of Overseas Entities.

This guidance note gives an overview of the rules that apply from 6 April 2019 with a focus on their application to non-resident companies under the ‘NRCG’ rules.

Detailed guidance on the rules that