Non-UK residents who own UK property or shares in UK property-rich companies face Capital Gains Tax (CGT) on their gains under the Non-Resident CGT (NRCGT) rules. The most critical practical point is the 60-day reporting deadline: from the date of completion, non-residents have 60 days to file an NRCGT return and pay any tax due -- whether or not they file a UK Self Assessment return. Missing this deadline triggers immediate penalties. This guide explains the rules for 2026/27, the applicable rates, rebasing options, treaty relief, and the 90-night PPR test.
The scope of NRCGT has expanded significantly since 2015. The current rules (post-April 2019) bring the following within the UK CGT net for non-residents:
Ordinary shares in UK trading companies (where UK property is incidental to the business) remain outside NRCGT for individual non-residents. However, non-resident companies with UK property interests moved from CGT to Corporation Tax from April 2019.
The 60-day rule is the most time-sensitive obligation for non-residents disposing of UK property. The clock starts on the day of legal completion (not exchange of contracts). Within 60 days, the non-resident must:
Penalties for missing the deadline begin at GBP 100 for a return filed up to 6 months late, rising to GBP 300 or 5% of the tax due (whichever is greater) for a return filed between 6 and 12 months late, and further escalating penalties after 12 months. Daily penalties of GBP 10 per day can also apply for returns between 3 and 6 months late. There is no exception for cases where no tax is owed -- the return must still be filed on time.
Non-residents pay CGT on UK property at the same rates as UK residents:
These rates reflect the upward revision in the October 2024 Budget, which increased residential property CGT rates (previously 18%/28%) and aligned them with commercial property. The basic-rate band allocation is determined by reference to the non-resident's UK income in the year of disposal -- only UK-sourced income is taken into account for this purpose, not worldwide income.
Rather than computing a gain on the full historic cost, non-residents have three calculation options:
The election must be made on the NRCGT return and is irrevocable once made. Each method should be modelled before filing to ensure the most tax-efficient basis is selected.
Non-residents can still claim PPR relief on a UK residential property that was their main home, but the anti-avoidance rules introduced in 2015 mean that non-residents must satisfy a strict occupation test for each tax year of non-residence. Specifically, the non-resident (or their spouse/civil partner) must have spent at least 90 nights in the property during the relevant tax year. If the 90-night test is failed for any year, PPR does not apply to that year's proportion of the gain. This rule prevents non-residents from claiming PPR on properties they rarely actually use as homes.
The UK has double tax treaties with over 130 countries. Most modern UK treaties follow the OECD Model, which allows the source country (the UK) to tax gains on immovable property -- meaning that treaty protection against NRCGT is limited for property gains. However, older treaties may provide more favourable treatment. If you are resident in a country with a UK tax treaty, you should check the specific CGT article and seek advice on whether any relief reduces the UK tax due. Any UK CGT paid can typically be credited against the equivalent tax in your country of residence, subject to that country's own foreign tax credit rules.
