Case Studies
Non-Resident Capital Gains: Key Changes & What Overseas Investors Should Know
UK’s rules on non-resident capital gains are changing from April 2026. If you’re a non-UK individual or company investing in UK property through a protected cell company (PCC), these updates matter.
By NomadicTax Research Team • 5-8 min read • April 13, 2026
## What is Non-Resident Capital Gains Tax (NRCG)?
For non-UK residents, disposals of UK land and property may attract Capital Gains Tax under the Non-Resident Capital Gains regime. Recent changes refine how entities are treated and clarify treaty-based claims. ([gov.uk](https://www.gov.uk/government/publications/capital-gains-tax-non-resident-capital-gains/non-resident-capital-gains?utm_source=openai))
## What’s changing?
- The **property-rich entity test** is being amended so that if you hold UK land/property through a **Protected Cell Company (PCC)**, only the individual cell is tested for “property richness,” not the aggregated company. ([gov.uk](https://www.gov.uk/government/publications/capital-gains-tax-non-resident-capital-gains/non-resident-capital-gains?utm_source=openai))
- Other administrative clarifications include how and when **double taxation treaty claims** must be made by certain individuals. ([gov.uk](https://www.gov.uk/government/publications/capital-gains-tax-non-resident-capital-gains/non-resident-capital-gains?utm_source=openai))
## When do these changes take effect?
- For **companies**: 1 April 2026.
- For **individuals**: 6 April 2026.
- The definition change for PCCs takes effect **from disposals made on or after 26 November 2025**. ([gov.uk](https://www.gov.uk/government/publications/capital-gains-tax-non-resident-capital-gains/non-resident-capital-gains?utm_source=openai))
## Who this affects
- Non-UK resident investors in UK land/property through corporate structures including PCCs.
- Individuals who may have made treaty claims and need clarity on how to do so.
- Entity-based investors considering mobile structure or offshore vehicle use.
## Example
**Investor A** owns UK property via a Protected Cell Company comprising three separate cells. Under the new rules, each cell is assessed individually for property richness, which may cause some cells now to meet the test whereas under old rules the aggregated company might not.
## Tasks for non-UK residents & their advisers
- Review existing investments in UK land/property via PCCs or other special structures. Does individual cell structure change your tax exposure?
- If treaty relief is used or anticipated, ensure claims are properly documented and aligned with clarified rules.
- Plan disposals or timing for asset sales to consider new effective dates.
## Compliance tips
- Maintain detailed records: structures, asset values, and cell-level ownership.
- Align with Corporate and individual NRGC declarations when filing.
- Seek specialist legal or tax advice where structures are complex.
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These changes reduce ambiguity and close loopholes. For non-resident individuals and companies using offshore or cell-based vehicles, this is a crucial update. Act now to avoid surprises in filing and liabilities. **Category: Case Studies**