Taxation of Chargeable Gains Act 1992 Schedule 4ZZB paragraph 8

Modified application of paragraphs 5 to 7 where election made for straight-line time apportionment

Paragraph 8 of Schedule 4ZZB provides an alternative method for calculating the non-resident capital gains tax (NRCGT) gain or loss on a disposal of UK residential property, where the person elects to use straight-line time apportionment instead of the default rebasing method.

  • Where a person elects for straight-line time apportionment, the NRCGT gain or loss is calculated by apportioning the total gain or loss over the entire ownership period on a time basis, and only the portion attributable to the post-April 2015 period is brought into charge.
  • The apportionment is made on a straight-line basis, dividing the total gain or loss by the number of days in the whole ownership period and multiplying by the number of days from 6 April 2015 to the date of disposal.
  • This election provides an alternative to the default rebasing approach (which uses the market value at 5 April 2015 as the base cost), and may be beneficial where the property has increased in value at a relatively even rate over the ownership period.
  • The election modifies the operation of the computational rules in paragraphs 5 to 7 of Schedule 4ZZB, replacing the rebasing calculation with a time-apportioned figure whilst preserving the overall framework for determining whether a gain or loss arises.

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