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Ask an expert: NRCGT rebasing


A client of mine moved from UK to France in summer 2020 and has now decided to stay. She has a number of UK buy-to-let properties that she holds through a Jersey resident company (JerseyCo) which were bought at various times between 2008 and 2017. She is planning to sell some of the properties. I know that UK CGT is payable on any gain but given the 2019 changes to NRCGT how does rebasing apply and are there any further considerations to bear in mind?


You are correct that UK NRCGT (in the form of corporation tax on chargeable gains) will apply on a disposal by JerseyCo of any of the buy-to-let properties it owns (TCGA 1992 s 2B(4)).

NRCGT (non-resident CGT) was introduced in the UK in 2015 applying to disposals of residential property by certain non-UK residents only (including individuals and closely-held companies). From the...

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