Readers’ forum: Mitigating capital gains tax liability of late client

For many years I have dealt with the tax affairs of a woman born in South Africa. After marrying a UK citizen she obtained dual nationality (ie she has South African and British nationalities).

Over 20 years ago the couple took up permanent residence in South Africa leaving their freehold property in the UK to be let through estate agents. Sadly her husband passed away during August 2017 leaving his wife as the sole owner of the property.

In September 2023 my client also passed away and the property will be sold shortly. I understand that this will inevitably attract a substantial capital gains tax liability.

The point that I would like to establish is whether the liability can be mitigated by way of concession or legislation considering that my client has been classed as non-resident in the UK for each of the past 20 years....