Sarah Squires (Old Square Tax Chambers) considers how the rebasing rules apply to a recent non-resident's plans to sell UK buy-to-let properties.
Question
A client of mine moved from UK to France in summer 2020 and has now decided to stay. She has a number of UK buy-to-let properties that she holds through a Jersey resident company (JerseyCo) which were bought at various times between 2008 and 2017. She is planning to sell some of the properties. I know that UK CGT is payable on any gain but given the 2019 changes to NRCGT how does rebasing apply and are there any further considerations to bear in mind?
Answer
You are correct that UK NRCGT (in the form of corporation tax on chargeable gains) will apply on a disposal by JerseyCo of any of the buy-to-let properties it owns (TCGA 1992 s 2B(4)).
NRCGT (non-resident CGT) was introduced in the...
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Sarah Squires (Old Square Tax Chambers) considers how the rebasing rules apply to a recent non-resident's plans to sell UK buy-to-let properties.
Question
A client of mine moved from UK to France in summer 2020 and has now decided to stay. She has a number of UK buy-to-let properties that she holds through a Jersey resident company (JerseyCo) which were bought at various times between 2008 and 2017. She is planning to sell some of the properties. I know that UK CGT is payable on any gain but given the 2019 changes to NRCGT how does rebasing apply and are there any further considerations to bear in mind?
Answer
You are correct that UK NRCGT (in the form of corporation tax on chargeable gains) will apply on a disposal by JerseyCo of any of the buy-to-let properties it owns (TCGA 1992 s 2B(4)).
NRCGT (non-resident CGT) was introduced in the...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
