Draft changes to the NRCGT regime legislation have been announced and are open to consultation until 25 October 2019.
On 17 September 2019 HM Treasury announced draft regulations for consultation which amend the existing legislation for the Non-Resident Capital Gains Tax (NRCGT) regime. The amendments are open for consultation until 25 October 2019 and are expected to come into force on 1 January 2019. Most of the changes will be retroactive from 6 April 2019. The amendments are being made following feedback received from professional investors and advisory firms on a number of practical issues that have been identified. The changes mainly correct minor errors in the existing legislation and clarify the way particular rules are intended to operate. The amendments specifically focus on the rules pertaining to collective investment vehicles (CIVs) and their investors.
The full draft regulations and the accompanying explanatory memorandum are set out here.
A high level summary of the key changes is as follows:
We recommend that all managers of and investors in CIVs review the new rules with a view to assessing their impact. However, we also recommend that where possible, no definitive action is taken until the updated regulations are finalised and the associated updated guidance is issued.
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