Postby AGoodman » Thu Aug 06, 2020 7:30 pm
1. Yes, if you arrive in the UK in July and remain here you will definitely be UK tax resident. One of the many tests for UK residence is spending 183 days here. See the Statutory Residence Test to confirm your exact position for this tax year. It may be possible to avoid this if you keep your time in the UK down but you will need to work through the Test.
2. You don't provide enough information to ascertain your treaty residence but it doesn't matter. The UK will always have the right to tax gains on UK land under the treaty.
The treaty will never render you non-UK resident under UK domestic law so you will never be liable to NRCGT, only regular CGT calculated on the normal method without rebasing.
The only solutions to get NRCGT treatment are: keep your days down to a level (the level may be 91, 121 or 183 days) where you are not UK tax resident OR don't sell until you have left the UK.