RG5.8 - Liability to UK tax: Scope of liability to Capital Gains Tax

StatusGains on disposal of
 UK assets 1Overseas assets
Resident and ordinarily resident, domiciledLiableLiable
Resident and ordinarily resident, not domiciledLiableLiable if received in the UK
Resident but not ordinarily resident, domiciledLiableLiable
Resident but not ordinarily resident, not domiciledLiableLiable if received in the UK
Not resident but ordinarily resident, domiciledLiable 3Liable 3
Not resident but ordinarily resident, not domiciledLiable 3Liable if received in the UK 3
Not resident and not ordinarily resident, domiciledNot liable 2, 4Not liable
Not resident and not ordinarily resident, not domiciledNot liable 2, 4Not liable
  1. There is no liability if the disposal is of certain UK Government Securities. See CG54900 onwards.
  2. Liability will arise if the assets were used or held for the purposes of a trade, profession or vocation carried on in the UK through a branch or agency or by the branch or agency. See CG25500 onwards.
  3. See Appendix 2 and the DT manual about possible relief under a DTA.
  4. Gains arising during a period of temporary non-residence may be chargeable (see CG26101 onwards).