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.