The Government has confirmed its intention to make UK residential property held indirectly by non-doms through an offshore structure chargeable to UK Inheritance Tax (IHT). As planned, this will begin on 6 April 2017. Although the proposal was first announced as far back as July 2015, draft legislation effecting this change was only published on […]
Read moreThe Autumn Statement on 23 November contained no further detail about how the Government’s proposals for achieving Inheritance Tax transparency for offshore structures from 6 April 2017 is going to work in practice. However, in rather ominous fashion, the Government did use the occasion to confirm that the changes are going ahead as planned from […]
Read moreWell advised non-doms know that UK situated assets should never be directly held by their offshore discretionary trusts. To do so would subject the offshore trust to periodic charges to UK Inheritance Tax (IHT). These charges comprise the entry charge, the ten year anniversary charge, and exit charges, where value leaves the trust after creation. […]
Read moreBuying a property is often the biggest investment a person will make in their lifetime. It therefore stands to reason that people want to ensure that their investment is protected. The recent case of Haque v Raja[1] provides a reminder that, if you don’t appear on the title of a registered property that you’ve contributed […]
Read moreOwners of UK residential property held through offshore structures, including non-UK companies and partnerships, should urgently review their structures following the publication of a further consultation by the UK Government on 19 August 2016. The consultation confirms that residential properties in these structures will be exposed to UK Inheritance Tax (IHT) from 6 April 2017. […]
Read moreHere we are in the brave new world of higher Stamp Duty Land Tax (SDLT) rates for certain residential property purchases. As from 1 April 2016, anyone buying an additional UK residential property, such as a second home or buy-to-let, faces paying a surcharge of 3% above the standard SDLT rates (see my blog of […]
Read moreIn the Autumn Statement last month, the Government proposed that purchases of additional residential properties in England, Wales and Northern Ireland should be subject to an extra 3% Stamp Duty Land Tax (SDLT) on top of the standard SDLT rates. All types of residential property will be caught – second residences, buy-to-lets or furnished holiday […]
Read moreThe Government has passed legislation which will increase UK tax bills for most individuals (whether UK resident for tax purposes or not) owning UK residential let property, where the property has been part financed through mortgage debt. The changes take effect from 6 April 2017. Those with high gearing and significant interest payments will be […]
Read moreThis is the first UK tax year in which non UK residents will be subject to Non Resident UK Capital Gains Tax (NRCGT) when disposing of their UK residential property to anyone other than their spouse/civil partner or to charity. Non resident trustees and personal representatives pay NRCGT at 28% on taxable gains and individuals […]
Read moreSuccessful Inheritance Tax (IHT) mitigation in respect of the main residence is one of the hardest things to do, as the law currently stands. However, as many people’s most valuable asset is their bricks and mortar, it is a problem that demands some consideration – even if the answer is to do nothing (yet) or […]
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