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Chapter CG73710

Document Cited in Related
Vincent
Published date12 March 2016
Record NumberCG73710
CourtHM Revenue & Customs
IssuerHM Revenue & Customs

The legislation applies a charge to non-resident CGT on disposals of UK residential property interests, but it allows persons who meet certain conditions to claim exemption from a charge.

The charge should broadly apply to companies that are directly or indirectly controlled by a small number of individuals. But the charge should not apply to entities that are part of a group with a diverse shareholder base, such as publicly listed companies or their subsidiaries, nor to entities that are, or are ultimately owned and controlled by, institutional investment schemes with a diverse investor base.

The aim is to ensure the charge applies to companies that are the private investment vehicles of individuals, families or other small groups. Unless the legislation contained suitable targeting provisions, it would be possible for persons who would otherwise be...

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