A client has been non UK resident for 10 years. Whilst abroad (and whilst non UK resident), he bought a UK residential property and has rented it out long-term.
He is now contemplating selling the property, and also is thinking about coming back to the UK permanently. He had a valuation done as at 6 April 2015 for CGT rebasing purposes. He has asked if he should sell before or after he resumes UK residence.
Has never lived there, nor were his intentions on purchase anything other than as a UK buy-to-let, so no PRR available. My view is that once he becomes UK resident he brings himself back into the UK CGT system entirely, such that his ENTIRE gain on the property will become taxable, without the benefit of re-basing as at 6 April 2015. However, I understand that for the new 'all UK property' rules wef 6 April 2019, companies who become UK resident on or after 6 April 2019 will retain the ability to calculate their gains or losses using rebasing to April 2019 market values; does this also apply to individuals who become UK resident?
Does the fact that he purchased the property whilst he was non UK resident mean that he will NOT come under the NRCGT rules (or do the NRCGT rules trump everything)? I suspect the answer is that the NRCGT rules trump everything.