Non-resident CGT rebasing means that when a non-resident sells UK property owned before the date non-residents became taxable, the gain is worked out from the property’s market value on that date instead of its original cost. For UK homes, the rebasing date is 5 April 2015. For commercial property and land, it is 5 April 2019. Only the growth in value after that date is taxed.
Rebasing is the default method, but for residential property you can choose time apportionment or the whole-period gain instead, whichever gives the best result. HMRC explains the options in its guide to working out your tax as a non-resident.
This guide explains how non-resident CGT rebasing works, when another method is better, how to value the property at the rebasing date, and a worked example where rebasing turns a gain into a loss.
How Non-Resident CGT Rebasing Works
Non-residents were first brought into UK CGT on residential property from 6 April 2015 and on all other UK land and property from 6 April 2019. To avoid taxing growth from before those dates, the law treats the property as if you had bought it at its market value on the rebasing date:
| Type of property | Rebasing date | Alternative methods |
|---|---|---|
| UK residential property | 5 April 2015 | Time apportionment or whole-period gain |
| UK commercial property and land | 5 April 2019 | Election to use original cost |
| Shares in UK property-rich companies | 5 April 2019 | Election to use original cost |
If you bought the property after the rebasing date, there is no rebasing. The gain is simply the sale price less the purchase price and allowable costs. See our guide to a non-resident selling UK property for the wider rules.
The Three Methods for Residential Property
- Rebasing: gain = sale price less the 5 April 2015 value and costs since then. Best when the property grew strongly before 2015.
- Time apportionment: the whole gain since purchase is spread evenly over the ownership period, and only the share after 5 April 2015 is taxed. Best when values were flat or fell after 2015.
- Whole-period gain: the full gain or loss since purchase. Mainly useful to claim a loss.
You choose the method when you file the return, so always work out all three. Our non-resident CGT calculator gives a quick comparison.
Worked Example: Non-Resident CGT Rebasing Creates a Loss
Elena lives in Italy. She bought a London flat in April 2008 for £300,000. It was worth £450,000 on 5 April 2015, but London values softened and she sells in April 2026 for £420,000. For simplicity, costs are ignored.
| Method | Calculation | Result |
|---|---|---|
| Rebasing | £420,000 less £450,000 | Loss of £30,000 |
| Time apportionment | £120,000 gain × 132 of 216 months | Gain of £73,333 |
| Whole-period gain | £420,000 less £300,000 | Gain of £120,000 |
Rebasing gives Elena no tax to pay and a £30,000 loss she can set against future UK property gains, as long as she reports it on her 60-day return. She must still file within 60 days of completion. See the non-resident CGT 60 day rule.
When Time Apportionment Beats Non-Resident CGT Rebasing
Rebasing is not always the best choice. Time apportionment usually gives a lower gain when most of the growth happened after April 2015, or when the property was bought long before 2015 and its value then was only slightly above the purchase price. For example, if a flat bought in 2005 for £200,000 was worth only £210,000 in 2015 and sells in 2026 for £320,000, rebasing taxes £110,000, while time apportionment taxes roughly half of the £120,000 total gain.
You can choose a different method for each property you sell, so run the numbers separately every time. Keep your workings with your records in case HMRC asks how the gain was calculated.
Valuing the Property at the Rebasing Date
The rebasing value must be the open market value at 5 April 2015 or 5 April 2019. A retrospective valuation from a RICS-registered surveyor is the safest evidence. Useful supporting data includes Land Registry sale prices of similar nearby properties around that date and any lender valuation from a remortgage.
HMRC can challenge a value that looks too high, which would increase the gain. If you have a valuation issue, our guide on how to report CGT to HMRC explains where the figures go on the return, and HMRC’s helpsheet HS307 covers the rebasing rules in full.
How Rebasing Interacts With Reliefs
- Private Residence Relief: with rebasing, only the period after 5 April 2015 matters, and each tax year abroad needs the 90-day test to qualify. Read what Private Residence Relief is and GOV.UK’s guide to tax if you live abroad and sell your UK home.
- Improvement costs: under rebasing, only improvements made after the rebasing date are deductible, because earlier work is already reflected in the 2015 value.
- Annual exempt amount: the £3,000 exemption applies after the method is chosen. See our guide to the CGT annual exempt amount.
Frequently Asked Questions
What is the CGT rebasing system for non-residents selling UK property?
It lets non-residents work out their gain from the market value at 5 April 2015 for homes, or 5 April 2019 for other property, so growth before those dates is not taxed.
Do non-residents get the CGT annual exemption?
Yes. Non-resident individuals get the same £3,000 annual exempt amount as UK residents in 2026/27.
How much was Capital Gains Tax in 2015?
In 2015/16, residential property gains were taxed at 18% or 28%. For sales in 2026/27, the rates are 18% and 24%, whatever date the property was rebased to.
Does Capital Gains Tax apply to non-residents?
Yes, on UK land and property and on shares in UK property-rich companies. Most other assets are outside UK CGT for non-residents.
Can I use rebasing if I was UK resident when I bought the property?
Rebasing applies to the disposal if you are non-resident when you sell. If you were UK resident in the tax year of sale, the normal UK rules apply instead and there is no rebasing.
Get expert help: Every situation is different, so speak to a qualified capital gains tax accountant before you act. Our non-resident CGT team can review your figures, and we also work with clients looking for capital gains tax advice in Manchester and across the UK.
Conclusion
Non-resident CGT rebasing usually means only the growth since 5 April 2015 for homes, or 5 April 2019 for commercial property, is taxed. For residential property, compare rebasing with time apportionment and the whole-period gain before you file, because the best method depends on when the value rose. A reliable valuation at the rebasing date is essential.
Report the result within 60 days of completion, even if rebasing gives a loss.
For help choosing the right method and valuing your property, speak to our non-resident CGT specialists. Call us on +44 (0)1204 859315 or send us your question for a free initial consultation and a fixed-fee quote within 24 hours.
