CGT on UK Property Reporting Service - a user's guide
Row of terraced houses with balconies and brightly coloured window surrounds

Latest update: 7 January 2026:  Since the last update in February 2025, we have updated the guide to tidy up the text and remove references to historic material, including the Agent Forum, which has now closed. 

As ever, corrections or comments to [email protected] are always welcome.

 

Introduction

Since its launch in April 2020, we have received a lot of feedback from members about how to tackle the CGT on UK Property Service. This service is used to report CGT arising on the disposal of UK residential property within 60 days of completion. This note sets out what we have learned to date about the practical process of reporting. It is based on publicly available guidance and correspondence with HMRC. It has not been reviewed by HMRC.

We have focused this note on reporting for UK residents, but there are some comments on non-UK residents below as they are also expected to use the service for their (wider) obligations to report both direct and indirect disposals of UK property.

While we have endeavoured to ensure this note is as accurate as possible, it is intended for general guidance only and no responsibility can be accepted by the Association of Taxation Technicians for loss occasioned to you or any other person acting or refraining from action as a result of any material in this document.

Comments, corrections or feedback from members are always very welcome. Please send them to [email protected].

 

Contents

What are the rules?

In brief, any UK resident disposing of a UK residential property on which a CGT liability arises must calculate, report and pay that CGT within 60 days of the completion of the sale. Reports must be made online, via the CGT on UK Property Service. The rules apply to individuals, trustees and personal representatives and are often referred to as the '60-day' reporting rules. They typically (but not exclusively) impact landlords and second home owners.  

The relevant legislation can be found in schedule 2 of Finance Act 2019.  When the rules were introduced in April 2020, taxpayers were given 30 days to report, but this was increased to 60 days for completion dates on or after 27 October 2021 at the Autumn Budget 2021. The amendment to extend the deadline to 60 days was included as part of Finance Bill 2021-22. 

The rules for non-UK residents are similar to the rules for UK residents but there are some key differences. Crucially, non-residents are required to report not just disposals of residential property, but all  disposals of UK land and property including commercial property and bare land. Non-residents must also report disposals where they have made a capital loss, or where there is a gain, but no tax is due. Non-residents must also report disposals of shares in so-called 'property-rich' entities. Detailed guidance on the rules for non-residents can be found in HMRC's manuals. 

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Guidance from HMRC

HMRC's published guidance on the service can be found in an appendix to their Capital Gains Tax Manual.  This guidance primarily focuses on the rules as they affect UK resident taxpayers. 

Any feedback or comments that members have on the manual pages would be very welcome. Please send them to [email protected] and we can pass these to HMRC. 

Alternatively, you can report queries or issues direct to HMRC for this - and any other GOV.UK pages - using the 'Report a problem with this page' button. This can be found in the pale blue banner at the bottom right of the page. 

More detailed feedback on GOV.UK pages can also be provided directly to HMRC using their contact form. This can be found by scrolling right to the bottom of the page and clicking the 'Contact' link. This should take you to a page titled 'Find contact details for services'.  At the bottom of this page it should say "Use the GOV.UK contact form to send your questions or comments about the website". Clicking on the link to the contact form will allow you to provide detailed questions or comments about the website and your contact details. 

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Can agents report on behalf of clients?

Yes. Agents can make a report on behalf of their clients online via the CGT on UK property service provided they have been specifically authorised to do so. Any existing 64-8 is not sufficient to allow an agent to submit a property return online. Agents and their clients are expected to carry out a digital handshake to confirm to HMRC that the agent is authorised to act.

Where the taxpayer is unable to use the online service, they will need to submit a paper return. The agent can complete this return for the client, but cannot sign it for them. There is no specific authorisation route for submitting a paper return, but if the agent already has a 64-8 in place, this should be sufficient to allow the agent to discuss a paper return with HMRC on their helplines. If members have any issues, please let us know. 

Where the agent is completing the CGT reporting as a standalone service using the paper return process, they should be careful about sending in a 64-8 to enable to them to talk to HMRC on the phone.  This is because the new 64-8 will displace any existing authority held by another agent. 

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Authorising the Agent - The Digital Handshake – a step by step guide

Guidance on the authorisation process is available on GOV.UK. The process assumes that the agent will have already set up an Agent Services Account (ASA). If not, they will need to create one. 

The steps are as follows:

Step 1: The client creates a Capital Gains Tax on UK Property Account   

Many people assume that they can set up their Capital Gains Tax on UK Property account  (‘Property Account’) from their Personal Tax Account (PTA). This is not possible. The CGT on UK property service can only be accessed from specific pages on GOV.UK and cannot be accessed from within the PTA.

However, it is helpful if the client already has a PTA as they can use the same credentials (by which we mean Government Gateway username and password) to set up their Property Account. We also understand that a sole trader with a Business Tax Account (BTA) instead of a PTA can use their BTA credentials to set up a Property Account.

Many people do not realise that an individual can use the same Government Gateway credentials for more than one service across GOV.UK. It is recommended that users have only a single set of credentials to access their PTA and do not, for example, set up a new set if they forget their original access credentials. HMRC ran a process during 2022 to help people consolidate multiple Government Gateways.

A client with existing GOV.UK credentials should follow the green ‘Start’ button from the Report and pay Capital Gains Tax on UK property pages and then sign in with those credentials. Creation of a Property Account in these situations should take less than five minutes.

If the client does not have any existing GOV.UK credentials, then they will need to set up a Government Gateway account first and verify their ID. They should follow the same green ‘Start’ button but then click on the link underneath the sign-in box which says ‘Create sign in details’ . They then need to follow the steps on screen to set up their username and password, before continuing on to create their Property Account.

At the end of the process, the client will be issued with a reference number for their Property Account. This will be a 15-digit number in the format XYCGTxxxxxxxxxx or similar. The client should make a note of this, as they will need it for future steps.

Some individuals can struggle to set up a Government Gateway - despite being otherwise quite capable of using a digital service - because they have no passport or credit history and cannot get through the verification process. In these cases, these individuals (or their agents) will need to use the interactive form online. 

Step 2: Client tells agent their details

Having created their Property Account, the client needs to send their 15-digit reference number and their postcode (or country of residence if non-resident) to their agent.

Step 3: Agent requests access

The agent logs into their ASA and selects ‘ask a client to authorise you’ to manage their Capital Gains Tax on UK Property Account.

The agent enters the Property Account reference details provided by the client, plus the client's postcode, which generates a time-limited link (it expires in 21 days) which they can send to the client by email.

Step 4: The taxpayer authorises the agent

The client receives the link and needs to approve the agent to act before the link expires. The taxpayer needs to use the same credentials (username and password) that they used in step 1. This will either be their existing credentials from a PTA/BTA, or the credentials they created specifically for this service.

Once the client has authorised the agent, the agent should receive an email to confirm that their appointment has been accepted.

HMRC recommend that the client keeps the email requesting authorisation as they can use the links it contains to remove the agent in the future if they wish. 

Step 5: The agent files the return

Once this process has been completed by the client, the agent should be able to file a property return on behalf of the client via their ASA. 

Once started, the return can be saved (completed or partially completed) for up to 30 days. This allows the agent to go back to the client for more information or send it to the client for approval before filing. Each time the agent logs back in to make a small amendment this extends the window for which the return is saved, meaning that the draft return will remain live for another 30 days. Members tell us that attachments are only saved for five days (HMRC's manual says seven), so if you leave a return for more than five days before logging back in, you may need to reattach any documents you wish to submit with the return.  

A client signature is not required for the filing itself but it is good practice to retain evidence of the client having approved the return before submission. 

Step 6: The taxpayer pays the CGT due 

Following successful filing, both the agent and the client will receive a confirmation email from HMRC.

The client can make a payment by logging into their Property Account and settling the amount due by debit card or bank transfer. It is also possible to pay by BACs - see the 'Other practical points' for more details, including some commentary on payment references, which can be confusing. 

The agent should be able to check that payment has been made by their client by logging into the client’s Property Account via their ASA. Equally, the client can confirm payment has been received by logging directly into their Property Account. Details of payments are available on the dashboard. You may need to allow three to five working days for the client's account to be updated for any payments made.

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What if my client is unable to complete the digital handshake? The use of paper returns 

If the taxpayer is unable to complete the steps above then they will need to use the alternative, paper route. 

Some clients will be digitally excluded - i.e. completely unable to appoint HMRC online or manage their own Property Account due to age, disability, remoteness of location or for any other reason, including religious beliefs. These clients will be eligible to file by post. Some clients may be digitally capable, but unable to verify their identity online - this can be an issue for students and also older people with less of a credit history. They too, will be eligible to file by post. 

Other clients will be digitally challenged – i.e. they do not fall within the criteria for digital exclusion but they will still struggle to handle the process by themselves. HMRC considers that this group should, with support, be able to complete the steps online. These clients are not strictly eligible to file by post. From September 2022, such clients should be able to access support from HMRC to authorise their client digitally following the steps in the 'telephone authorisation' route below.  

Finally, some groups are required to file by post. These include:

  • Corporate trustees
  • A secure or Public Department 1 taxpayer who doesn’t file returns online with HMRC (generally MPs and judges) 

Further examples of groups which can use the paper return are available in HMRC's manuals in section 1.13.

Using the interactive form to generate a paper return    

The digital service is the default option for completing returns as HMRC consider that the online service is the most secure and efficient way to notify them of a residential property disposal and pay the CGT that is due. It is also possible to amend returns electronically and make and track payments. 

Since April 2024, as an alternative to the digital service, HMRC have provided an interactive form which can be completed online, printed and then posted to HMRC. Agents can use the form to report on behalf of clients. If the taxpayer or agent cannot use the interactive form, or needs one for the 2020-21 tax year, printed forms can be requested from HMRC helplines. 

The interactive form does not require the taxpayer to have a Government Gateway. It is not possible to save and return to the form, so it needs to be completed in one sitting.  After 15 minutes of inactivity the form will 'time out' and answers will be deleted. 

The interactive form will ask if the taxpayer has a Property Account reference. For a client’s first report, where the client has not previously set up a Property Account, this can be left blank. The reference number will be generated and added later by HMRC when the form is processed.

Where the interactive form is used for any amendments – or disposals of further properties -  the taxpayer's Property Account reference number should be added. The reference can be found on correspondence from HMRC resulting from the first paper return. 

Making payment following submission of a paper return

When filing a paper return, until the return is processed and a payment reference is received, it is not possible to make payment of the tax due. The instructions on the return, and HMRC's manuals at 1.71, confirm that "A Payment reference is issued when a paper return has been processed. HMRC will send a payment reference including the date the payment is due along with details of how to pay. Payments made to this reference will be applied directly to the charge for the return disposal."  

Some people will try to make a payment by using an existing Unique Taxpayer Reference (UTR). This should be avoided, as the Property Account is a completely separate system from the self-assessment system. Where a payment is to an existing self-assessment record, contact HMRC to ask for it to be moved and reallocated. 

As it's not possible to make payment until a reference has been received, many people worry about how the delay between submitting a paper return and receipt of a payment reference affects the 60 day deadline in which payment must be made. HMRC appreciate this and will ‘stop the clock’ (i.e. pause the 60-day count) during the period between the receipt of a completed paper return and the issue of a demand. This means that the taxpayer is not penalised for the parts of the reporting and payment process which are outside of their control. 

Another common issue is what to report on the self-assessment return if a paper return has been submitted but the payment reference has not yet been received. HMRC have provided some guidance on this issue in their manual at 3.2.5. 

The telephone authorisation process 

As an alternative to issuing a paper return, HMRC told us that they will assist digitally excluded taxpayers to appoint the agent by phone.  While this is a more time consuming route for agent and client, it could be more beneficial in the long run as the agent gets full access to the digital service on behalf of their client. This may be worthwhile where a client has a number of properties to sell, where it is suspected that amendments might be needed, or if the agent wants to check tax payments have been received.   

The type of help given on the telephone will depend on whether helpline staff consider the individual is digitally excluded – so that all the work needs to be done by HMRC -  or if they can be assisted and supported by HMRC or a third party (agent, family or friend) to set up Government Gateway credentials and manage it online themselves.

The determination of whether an individual is digitally excluded will be made by the HMRC helpline staff. They will triage calls to the Extra Support team to give the appropriate support. The test for digital exclusion, as noted above, is the same as for MTD for VAT and clients may be asked to explain why they consider themselves digitally excluded. We have previously asked HMRC for more guidance on how they are determining whether taxpayers fall into digital exclusion as we were concerned that the Extra Support team is very small and could be overwhelmed by requests for help. In practice, this does not appear to have been an issue, but agents may prefer to assist their digitally challenged clients themselves where possible to get through the handshake, rather than pass them over to HMRC.  

HMRC have provided us with the following steps for a digitally excluded client to give their agent access to their Property Account:

  • The agent asks their client to contact HMRC Taxes helpline on 0300 200 3300 to register for a Property Account (ask for a CGT on UK Property Account).
  • HMRC Taxes helpline advisor will confirm that client is digitally excluded and refer them to a tax technician
  • HMRC's Tax Technician will help the client register for a Property Account. This process will be done by phone or face to face, as appropriate.
  • The registration process will generate a Property Account reference number for the client. The reference number will be created in real-time and provided to the client.
  • Client must then give the Property Account reference number to their agent to begin the next step of the agent-client authorisation process.
  • Agent logs into Agent Services and selects ‘Ask your client to authorise you’.
  • Agent enters their client’s Property Account reference number, creating an invitation link. (In the normal digital handshake process this would be emailed to the client to follow. We presume that the link doesn’t actually need to be sent out for a digitally excluded client, just created at this stage so it is on HMRC’s systems.)
  • Client contacts HMRC Taxes helpline again (0300 200 3300) to request support to authorise their agent to access their Property Account (again, in full, the CGT on UK Property Account)
  • This time, the client may need to be referred to HMRC's Extra Support Service. It is possible they will need to wait for a call back.
  • HMRC Extra Support Service advisor will use client’s Property Account reference number to identify agent-client authorisation request and confirm that the client is happy for agent to act on their behalf. The adviser will then create the agent-client relationship.
  • Agent should then be able to engage digitally with HMRC on behalf of client for CGT property disposals.

We understand that the same approach can be followed for a digitally challenged client, but they may be expected to complete the online steps themselves, with support from HMRC. Again, the agent may prefer to assist if they are in a position to do so. We understand that HMRC would appreciate it if the agent could assist.

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Reporting without an agent

Taxpayers can report their gains without an agent if they wish. To do this, they need to set up a Property Account as described in Step 1 above. 

Where an unrepresented taxpayer is unable to set up a Property Account, they can use the the online interactive form to print and post their property return.

If they are completely digitally excluded, and unable to use the interactive form, they will need to ring HMRC to request a form, or ask to complete the whole process of reporting the gain over the phone with the Extra Support Team.

Further instructions and guidance for taxpayers tackling their own reporting can be found on the LITRG website.

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How to amend returns

Amendments can only be made in specific circumstances as set out in paragraph 15 of Schedule 2 of Finance Act 2019. 

These include if:

  • the estimate of the individual's income changes so the rate of CGT which applies is changed
  • the value of any figure which has been estimated or apportioned becomes known
  • it becomes reasonable to conclude that a relief under TCGA 1992 (for example hold-over relief) will now apply
  • a provision of TCGA 1992 will now apply because of the individual' s residence status. 

Other amendments relating to things not known at the time of the original disposal (for example capital losses which occurred after the completion date) must generally be dealt with through self-assessment. Paragraph 19 of Schedule 2 of Finance Act 2019 restricts what amendments can be made to the property return after it has been submitted. 

Once the individual's self-assessment return has been submitted, it is not possible to make amendments to any property returns made in that tax year. In effect, the self-assessment return will supersede the property returns.  

Individuals who are not in self-assessment have 12 months from 31 January following the tax year of disposal to amend their property return. 

Making amendments online

Only returns which were originally submitted online via the CGT on UK Property service can be amended online. 

Individuals managing their own affairs, and agents acting on behalf of a client should be able to access their/the clients property accounts and click on 'View or change return' under the Sent Returns section, and then click on 'Change return' at the bottom of that screen. 

Amendments resulting in a repayment – online approach

Where the amendment results in a repayment, HMRC have told us that bank details can be input into the digital online service for a repayment to be issued. 

In practice, there is no separate screen to enter bank details. HMRC have advised us that bank details can be attached as a separate document in the ‘upload file’ section.

Amendments to a paper return submitted by post 

Where the original return was submitted on paper, the amendment must also be made using a paper return. Another interactive form should be completed to include the amendment and then printed and posted to HMRC. If it is not possible to use the interactive form, another paper return will need to be requested from HMRC helplines. 

Interest on additional tax payable

An amendment may result in additional tax. HMRC confirmed to us that, provided reasonable estimates were used at the time of the report, and the box highlighting that the return contained an estimate was ticked, interest will not be charged if the initial payment on account is subsequently found to be insufficient. HMRC will charge interest if an estimate was used, but not indicated on the return.

In practice, since it will be necessary to estimate the income figure at the time of the return in almost all cases, we expect most returns will need to indicate that an estimate has been used. However, HMRC's manual at 2.5.2 highlights that if the only estimate on the return is the taxpayer's income, and they are confident that the CGT amount will not change (for example where it is already clear that the taxpayer's income is going to be such that the gain will be all taxable at 24% regardless of the final income figure) then there is no need to tick the estimate box.

HMRC will not issue reminders to anyone who has indicated that an estimate was used on the return. If the estimate needs updating, it is up to the taxpayer/their agent to keep track of this. 

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Interaction with self-assessment  

The SA108 pages of the self-assessment return include additional boxes - Boxes 9 and 10 - in the residential property section to allow the inclusion of in-year reports in the final self-assessment position for the taxpayer. In general, UK resident taxpayers should report the total of any disposals of UK residential property in box 9 and the total tax payable through the system in box 10.  

Our understanding is that the figures in 9 and 10 should be the totals of the latest submitted versions of the in-year forms prior to the filing of the self-assessment returns. The actual, final gains or losses on property should be included in boxes 6 and 7 as appropriate. The 'white space' in box 54 should be used to report the reference numbers of the property returns.

These instructions do not apply if the individual is entitled to Business Asset Disposal Relief (BADR) – see the separate note below under ‘Other practical matters’.

As noted above, our understanding of the legislation is that amendments to the property return can only be made in specific circumstances. For those in self-assessment, final adjustments to the return figures which cannot be made via the property return should be made via self-assessment. 

Overpayments 

Where the final CGT figure is higher than that demanded on the property return, the self-assessment computation should include the extra tax due.

Where the final CGT on residential property is less than that reported on the property return, from 2021/22, any refund due should be automatically offset against any income tax liability.  

If the income tax liability is less than the refund, so that there remains an amount due back to the taxpayer, it is necessary to ring HMRC to request the refund.  Repayments will not be issued automatically and therefore either the agent or taxpayer must contact HMRC to arrange for a repayment. HMRC’s manuals say that without contact, sums will be automatically off-set against other self-assessment liabilities if that is applicable.

We were previously advised that repayments would arise automatically if they were reported via the Property Return and the original payment was made by a card payment but HMRC’s manuals are now saying that repayment will only be made via debit card, without any clear indication that this will occur automatically. Accordingly we would recommend that agents/taxpayers contact HMRC in *all* cases where a repayment has arisen to be sure that it will be processed.

To add to the challenges of obtaining a repayment, the system does not show if a refund is due – this has now been confirmed in HMRC’s manuals so appears to be a feature not a bug.

We are aware many members will be dissatisfied with the proposed approach, but because of the way HMRC's systems are set up, it is currently impossible to automate a solution.  We have discussed with HMRC whether processes can be improved for future years but this seems unlikely. 

What to do when the self-assessment return has been filed before the property return

HMRC confirmed in Agent Update 95 in April 2022 that for an individual in self-assessment, the property return must be submitted before any self-assessment return is completed. The system will block the submission of a property return online if a self-assessment return has been filed. Although there are some limited circumstances (as set out under ‘Other practical points’ below) where a tax return can replace a property return, in general, the submission of a self-assessment return including the property disposal will not satisfy or remove the in-year reporting requirements.

HMRC confirmed on 20 July 2022 that:

“In the situation when a taxpayer has already made an SA return and not completed a UK property return then they should complete a paper return. They should follow the normal process for doing this and contact HMRC.”

This is also now confirmed in HMRC guidance. This means that where, for example, a 2024/25 return was filed reporting a property disposal, but no property return was submitted prior to the self-assessment return, the taxpayer should rectify the position by filing a property return on paper as soon as possible. We were advised at a meeting with HMRC in July 2022 that taxpayers/agents should note on the paper return that the disposal has already been reported and the CGT paid via self-assessment.

We were originally told that the approach of using a paper return to correct the position was a short-term position. That said, we are some years now down the line from this discussion and we assume that the costs are such it has not been possible to introduce this. Hopefully many of the issues with the separate CGT service will be resolved when MTD for Income Tax is rolled out. 

Where a paper form is submitted late this may have penalty implications. 

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Reporting for trusts

UK trusts fall within the CGT reporting rules, meaning that trustees will need to report disposals of any UK residential property within 60 days of completion if there is CGT to pay. 

Trustees can report online or using the interactive form. Corporate trustees are not able to use the online service and will need to use the interactive form. 

A number of members have queried the interaction between the CGT on UK property reporting service and the Trust Registration Service (TRS), particularly where the trust is not already registered on the TRS, or is only registered as a non-taxable trust. We have received a number of reports of property returns without a trust UTR being rejected. 

HMRC have told us that they expect a trust to register on the TRS prior to reporting the property disposal so that the trust can provide a UTR as part of the CGT reporting process. Where a trust is already registered on the TRS as a non-taxable trust, but becomes taxable as a result of a property disposal, HMRC stated in January 2025 that the trust will need to be updated to a taxable trust on the TRS before the property return is submitted in order to obtain a UTR. If this is not done, HMRC will reject the form. HMRC advise that if a form is rejected, the taxpayer will be given 28 days to resubmit. 

HMRC manual TRSM40030 has been updated to reflect HMRC's position. 

A number of members have raised concerns about this approach, on the grounds that the requirements of the TRS and of 60-day reporting are separate and the deadlines for registering on the TRS are generally longer than the CGT reporting deadlines. In addition, registering on the TRS will mean the issue of a UTR and a notice to file. In some cases, where there is no other income or gains to report beyond the property disposal, this will create additional, unnecessary, reporting for the trust. 

We have agreed to raise this with HMRC, but we felt it would be helpful for members to be aware of HMRC's preferred practice to avoid the risk of property returns being rejected. 

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Reporting for estates

Estates disposing of property fall within these rules, with personal representatives (PRs) required to report property disposals within 60 days of completion where a gain arises.

Reporting by the PR themselves

HMRC has guidance on how unrepresented PRs should tackle the process. (NB The term capacitor is not widely used but we have previously confirmed with HMRC that it does not include an agent.) 

It is not possible to set up a Property Account for the estate itself, so HMRC advises at PRs to report using their own Property Account. 

When starting a new report, the taxpayer is given the option of reporting on behalf of:

  • Themselves
  • Someone they are helping
  • An estate as a personal representative

Having selected the final option, subsequent screens will ask for details of the estate. On completion, the PR should receive a submission receipt.

*Health warning*  Once the property return has been submitted, estate cases go into a manual system. This means that, once submitted, it is not possible for the PR to log back in to view the return, make amendments or make a payment. It effectively 'disappears' from their account. Accordingly HMRC guidance advises personal representatives to download or print a copy of the return for future reference. 

Once the return has been submitted, HMRC will write to the PR requesting payment. The letter will confirm the due date. The PR can expect to be asked to pay within the later of 30 days of HMRC issuing the demand or 60 days from completion. 

This approach is intended to prevent payments in relation to an estate being offset against any of the PR's personal CGT liabilities. 

Reporting by an agent

An agent is not able to set up a Property Account in the name of their firm. Agents only have access to the CGT on UK Property reporting service via their ASA - which means they cannot follow the steps above.

In effect there is no specific functionality for agents to report digitally on behalf of estates/personal representatives and there is unlikely to be any such functionality in the near future - which leaves agents using paper returns in these cases.

However, since anyone with a property account has the option of reporting on behalf of another person, HMRC have noted that it is possible for the executor to appoint an agent to use their own, personal property account to report the disposal by the estate.  The usual digital handshake process would be required. 

There are some caveats to this approach:

  • The agent will be able to see any reports of disposals made personally by the executor – which may not be appropriate in all cases.
  • Appointment of the agent for the estate will displace any agent already appointed for the executor’s personal affairs.

Digital reporting for an estate will therefore only be suitable where the agent also acts for the executor in a personal capacity. Where the executor is a professional such as a solicitor, then the paper form will probably remain the best approach. 

Interaction with informal procedures

A further concern for estates is the interaction between the reporting requirements under the 60-day reporting rules, and the informal procedures for an estate.

Under the informal procedures, a non-complex estate does not need to register for a UTR (which would be obtained via the TRS), but instead the PRs or their agent submit an account by letter after administration is complete.

Informal procedures are available provided that the total tax due under self-assessment (i.e. CGT and Income tax) for the entire administration period is under £10,000, the estate is under £2.5m and the value of assets sold in any tax year are under £500,000. The idea is that this informal approach is simpler and more cost effective than completing tax returns for the period of administration.

It is possible for an estate to make a property disposal such that it remains within the informal procedures (so no need for self-assessment or a UTR) but still be within the rules for reporting and paying CGT within 60-days on a residential property disposal. HMRC have confirmed that such an estate can still benefit from the informal procedures and will not be forced into self-assessment as a result of the property reporting requirements - although they will need to complete any required property report in the usual way.

The options for reporting are to use a paper return (where an agent is acting) or for the personal representative to use their own Property Account to submit a Property Return on behalf of the estate as noted above.

When the estate comes to finalise the tax for the period of administration through the informal procedures, the PRs will need to quote any reference numbers relating to the previous CGT payment to enable HMRC to link both payments together. This may include details of the PR's Property Account, and care will be needed to clearly identify the relevant estate disposal if the PR has also reported gains made in their own name.

Finalising the estate’s affairs

As a final comment, in their August 2020 Trust and Estates newsletter HMRC noted that if the estate opts to finalise its wider tax affairs (i.e. files a self-assessment return or makes a report under the informal procedures which includes the CGT on the property disposal) within 60 days of completion of the property sale, then there is no need to report via the Property Account at all. This will potentially be of benefit in those cases when the property sale occurs just before the estate administration is completed.

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Reporting for non-resident individuals

Non-resident individuals have had reporting requirements since April 2015 for disposals of UK residential properties. Their obligations were expanded in April 2019 to cover direct and indirect disposals of all UK land. On 6 April 2020, the reporting route for non-residents was also moved to the UK Property Reporting Service.

The process for non-residents generally follows that for residents. The primary issue for non-residents is establishing their identity in order to create a Government Gateway account.

Where a non-resident does not have a NINO or UTR there is an alternative process to enable the creation of access credentials for non-residents. 

We have had reports from members that not all non-resident clients have been able to complete this process.  We are very grateful that a member has shared a step-by-step guide to setting up a non-resident account which other members may find helpful in assisting their clients. The guide was prepared in May 2024 and users should be aware that steps in the process may be changed by HMRC as systems are updated. The guide is supplied on an 'as is' basis with no guarantee of completeness or accuracy. 

If the non-resident does have a NINO or UTR, then as part of the process of setting up a Government Gateway they will be asked for a UK address – which they may not have. In these cases, HMRC has advised that the taxpayer should call the helpline on 0300 200 3300 to be talked through the registration process.

If online access cannot be achieved, a paper return will be needed. As noted above, since 6 April 2024 it has been possible to complete an interactive form on GOV.UK to generate a paper return which can be posted to HMRC. However, this will need to be signed by the client which can introduce further delays to the process. We understand that HMRC is looking for an original 'wet' signature. We have asked HMRC whether electronic signatures for non-residents would be acceptable but at present, this is not permitted.

If members experience issues with access for non-residents please send us examples where this has proved difficult – or impossible – so we can feed this back to HMRC.

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Other practical points

Making a payment

Payment of CGT due under 60-day reporting needs to be made via the CGT on UK Property Service - not via the usual self-assessment routes - so that it can be allocated to the taxpayer's Property Account. 

During the process of reporting, the taxpayer will be issued with two payment references at different stages of the process:

  • The 'payment reference number' which relates to the individual property return.
  • The 'payment reference' (which is the same as the taxpayer's Property Account reference).

The former allows the taxpayer to make a payment in respect of the tax due on an individual return. The latter allows the taxpayer to make a single payment to cover the outstanding tax on all the returns submitted on that Property Account.

HMRC have confirmed that taxpayers paying on their own account can make payment using either reference number. 

More care with references needs to be taken when an individual has used their Property Account to report on behalf of another person - for example if they have reported on behalf of a family member or an estate. In these circumstances, the individual 'payment reference number' should be used to ensure that the correct funds are allocated to the relevant submission and not allocated to any other disposals that individual may have reported personally.

If the client is able to engage digitally with HMRC, they can settle the tax due by logging into their Property Account and following the instructions to settle any outstanding tax via debit card or by bank transfer. They can also log into their account to confirm that payment has been received and matched to their account once the payment has cleared.  Three to five working days should be allowed for payments to clear.

Further details about making payment can be found in HMRC’s manuals. 

Making payment following submission of a paper return

Where a paper return has been filed, HMRC confirmed to us in September 2022 that the correct process to make payment is to wait until a payment reference has been issued. This is stated on the paper return and on GOV.UK. 

Payment will be requested by the later of 30 days of the issue of the manual charge or 60 days from the completion date of the property transaction. 

Delays in processing paper returns can lead to delays in receipt of any demand for payment. Members are welcome to report delays or concerns about processing times to us at [email protected]. 

A common question is what do if the taxpayer wants to file their self-assessment return, but the paper return has not yet been processed and they are unable to make a payment. HMRC's manuals at 3.2.5 suggest that the tax reported as due on the property return should be included on the return, but the lack of a payment reference should be disclosed in the white space. 

Payment by instalments

HMRC confirmed to us in 2022 that the legislation regarding instalments (s280/1 of TCGA 1992) does apply to property disposals. Guidance on payments by instalments is available in HMRC's manuals.

Where a paper return has been submitted, an election to pay by instalments can be made at the same time by attaching a letter with the return.

Where the return is submitted online, the election request can be uploaded to the service. However, this will not be automatically reviewed, so the taxpayer/their agent will need to ring HMRC to ask them to consider the instalment request. 

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Reporting disposals of mixed use, residential and non-residential properties

When a taxpayer disposes of a property which is partly residential and partly non-residential, it is necessary to determine the residential element of the gain and report it within 60 days. For the purposes of the property return, the gain should be split between the residential and commercial elements first, before starting the report, and only the residential element included. It is not possible for example to report the entire gain on the property, and then split out the residential part at the end of the process.

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Deleting or cancelling returns

It is not possible to delete or cancel a submitted return. In the unusual circumstance of requiring to delete or cancel a return which has been submitted erroneously, we have previously been advised that it will be necessary to contact HMRC and ask them to update the system manually. 

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Reporting the disposal on a subsequent self-assessment return

Where the individual is also within self-assessment, it will be necessary to report the disposal twice - once within 60 days and then again on the relevant self-assessment return. CGT computations are not currently pre-populated into self-assessment returns. Again, our best hope for improvement here is that this is addressed via MTD for Income tax.  

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Completing self-assessment prior to deadline for property return

In a few, limited cases, it may be possible for the individual to report the gain just once, via their self-assessment return. This can happen when the individual is able to file their self-assessment return before the 60-day deadline for the property return.

For example, if the exchange occurred on 2 February 2026 (resulting in a 2025/26 disposal, assuming an unconditional contract), followed by completion on 10 April 2026, the individual has until 9 June 2026 to make their property report. If they can submit their 2025/26 self-assessment return - including the property disposal -  before 9 June 2026, then this will in most cases remove the obligation to complete a property return as well.

In these situations, any CGT due will not be payable until the usual 31 January deadline - in this example 31 January 2027.  

Full details on when reporting via self-assessment does remove the requirement to submit a property return can be found in HMRC's manuals at 2.6.2. 

The only time this will not be effective is if the CGT due under the 60-day reporting rules exceeds the CGT due on the disposal in the self-assessment return. (This can be possible because of the timing of losses for example.) In these cases, even if the self-assessment return can be made within 60 days of completion, a property return is still required, and any CGT must be paid within 60 days as usual. However, as a concession in these cases, HMRC will allow the taxpayer to pay the lower, final CGT amount as calculated in the self-assessment return, rather than the higher sum in the property return. This avoid the taxpayer having to overpay and then recover the difference later. 

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How to deal with the error message 'we're experiencing technical difficulties'

It can be difficult to access a property account if the taxpayer's address is not correctly formatted in HMRC's systems. Where taxpayers get the message that the service is 'experiencing technical difficulties', it may be worth trying one of the 'fixes' below, depending on whether the taxpayer is resident in the UK or overseas.

Details received: 

If you are seeing a technical difficulties error message when signing in please follow one of the instructions below.

If you live abroad

Could you please check and if necessary update the address held in your Personal Tax Account.

Sign in and select ‘Profile and settings’ at the top of the page. Then select ‘Change' from alongside main address. In addition 'Change' from alongside postal address if you also have a correspondence address. When entering the address could you ensure that in the ‘Country’ field you enter your country of residence. This should not be entered in a field above this one. If you start typing in the box a drop down of countries to select from should appear. Select the relevant one and then save the address entered.

Please note that the account homepage may appear to show the correct address therefore you will need to follow the above in order to check that the country field is correctly populated.

Once this has been completed and saved, allow 24 hours and then sign into the Report and Pay Capital Gains Tax on UK property service. You should then be able to subscribe to the service and create an account, following which you will be able to file a return.

If you encounter a problem when trying to correct the details please contact the Income Tax helpline, link below.

If you live in the UK

Could you please check and if necessary update the address held in your Personal Tax Account.

Sign in and select ‘Profile and settings’ at the top of the page. Then select 'Change' from alongside main address. When entering the address could you ensure that the postcode is entered in the postcode field, and not within a field above this one.

Please note that the account homepage may appear to show the correct address therefore you will need to follow the above in order to check that the fields are correctly populated.

Once this has been completed and saved, allow 24 hours and then sign into the Report and Pay Capital Gains Tax on UK property service. You should then be able to subscribe to the service and create an account, following which you will be able to file a return.

If you encounter a problem when trying to correct the details please contact the Income Tax helpline.

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Interaction with top-slicing

As part of the calculation process, the taxpayer needs to provide an estimate of their income for the relevant tax year. The service asks for the individual’s gross income and the notes warn individuals not to include ISA income, tax credits etc. However, care should also be taken when the individual has any chargeable event gains (CEGs). In these cases, the taxpayer may need to adjust the income figure so they only include the top slice of any CEGs, so that the calculator gives the correct figure for tax. 

This is probably best illustrated by example.  In 2025/26 a UK individual has £15,000 of employment, and makes a £5,000 chargeable event gain. They also sell a residential property and realise a substantial gain. When calculating the CGT on the property they need to know how much of the gain is taxable at the basic rate of 18% and how much at higher rate of 24%. With the figures given, they might take their gross income to be £20,000 and conclude that they have £30,270 of basic rate band available. 

However, for the purposes of the CGT rates applying to the gain, they only need consider the ‘top slice’ of their life insurance policy. Let’s say that this policy has been held for five years so that the top slice is £1,000. For CGT rate purposes the individual has only used up £15,000 + £1,000 = £16,000 of basic rate band and £34,270 of the gain can be taxed at lower rates.

For those in self-assessment, most software packages should make the necessary adjustments automatically and any differences will be corrected at this stage. But individuals not within self-assessment who have realised a CEG could easily miss the point. HMRC's service will not highlight this as it doesn’t ask for a breakdown of their gross income figure so it is up to the individual to supply the income figure that gives the correct result.

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Claiming Business Asset Disposal Relief 

Business Asset Disposal Relief (BADR) can be claimed on the Property Return itself by selecting ‘other’ in the reliefs section and manually overriding the CGT figure. A computation showing how the CGT has been calculated will be required.

When it comes to self-assessment, further steps will be needed. As noted, under interaction with self-assessment, for UK Residents who are reporting disposals again as part of their self-assessment the gains need to be included in boxes 6 and 7 as required and the total of UK residential property disposals and tax paid separately identified in boxes 9 and 10.

HMRC's SA108 guidance notes highlight an exception where the gain reported qualifies for BADR. If this is relevant, please follow the latest guidance notes for the correct boxes to use and what notes to make in the white space.

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Supporting evidence

Whether or not the property service will request additional supporting evidence depends on whether or not HMRC's calculator produces a figure that agrees with the taxpayer's computation. 

If the system calculator gives an answer that the taxpayer agrees with, there is no need for the taxpayer to upload their calculation. If the taxpayer does not agree with HMRC’s calculation, then they will be asked to supply their calculation. In either case, any further evidence such as completion statements are optional.  

The paper return requests evidence such as calculations, invoices, receipts or valuations in all cases.

While we consider it reasonable to supply a computation when the figures differ from HMRC’s, we suggested to HMRC that to supply copies of other documents (particularly for every paper return as suggested) seemed excessive.

HMRC told us that there is no definitive list for what the taxpayer should supply and they should attach whatever they would have supplied to accompany a CGT disposal on a self-assessment tax return. Members should therefore use their judgement regarding what, if any, further information to supply. More details on HMRC's view on what information should be attached is included in their manuals at 2.5.5.

*Health warning* Attachments are only saved for five days. Agents/taxpayers should therefore take care if they log out and leave more than five days before returning they will need to reattach any documents prior to submission. We understand there is a warning message within the system. 

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Change in client address

Clients with a Property Account who change address will need to update their Property Account with their new address as well as notifying HMRC in the usual manner for any other tax purposes including self-assessment. 

As a stand-alone service, taxpayer addresses need to be updated separately on the CGT on UK Property Service. 

Taxpayers can change their address by logging into their Property Account and selecting the relevant option under ‘Manage account’ tab from the CGT account homepage. 

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Daily Penalties

Where a return is filed late, HMRC will issue penalties.

  • The initial late filing penalty is £100.
  • If the return is more than 6 months late, a further penalty of the higher of £300 or 5% of the tax due is charged.
  • The same penalty is charged again if the return is over 12 months late.

In August 2022, HMRC confirmed that daily penalties have not been charged for UK residents disposing of residential property. This follows the decision not to charge daily penalties for similar reports for non-UK residents. 

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Reasonable excuse

Where penalties are charged, these can be appealed if there was a reasonable excuse for late filing. We recommend that members document the reasons for any delays during the reporting process to support a reasonable excuse claim in the event of penalties.

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Summary

We continue to work with HMRC to highlight areas where we consider that there are gaps in the guidance or process issues. Feedback and comments from members are always welcome, particularly those which identify any errors in this note. 

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