Introduction Summary
1.Section 65 introduces Schedule 25 which introduces a charge to capital gains tax (CGT) on both UK and non-UK resident non-natural persons (NNPs) in respect of gains accruing on the disposal of interests in high value residential property that are the subject of the annual tax on enveloped dwellings (ATED). Broadly, for the purposes of this legislation NNPs will be companies and certain collective investment schemes. Companies that are within the charge to UK corporation tax will be liable to this CGT charge in respect of such disposals rather than corporation tax. The charge will apply to gains on disposals on or after 6 April 2013. Increases (and decreases) in the value of property before then are outside the new charge but remain subject to the existing corporation tax rules on capital gains. This legislation should be read alongside the legislation introducing ATED.