Readers' forum: Rebasing

Our client is a disillusioned Brexit farmer (DBF) who is thinking of selling substantial land for development. He was considering whether to become non-resident remembering the old ‘three tax years away’ rule but was disillusioned to find this had increased to five years and that there are new rules for non-resident capital gains tax returns and rebasing. But when this was looked at in detail it was difficult to confirm that rebasing applies here.

There are attractive UK tax alternatives available to DBF such as rollover relief (thus replacement relief for inheritance tax) entrepreneurs’ relief and a 20% rate of capital gains tax. However the lure of escaping overseas to a non-resident position with a vineyard looks attractive with all the Brexit fuss and worries over ‘wealth tax’.

Can readers explain if and how they think rebasing applies and how many years DBF must be non-resident and ideally...