Michael Thomas (Pump Court Tax Chambers) looks at the rules introduced in the recent Budget intended to ensure that profits from a trade dealing in or developing UK land are always chargeable to UK corporation tax or income tax.
For many years some taxpayers have sought to shield profits from trading and developing UK land. Their approach is to have the relevant activities carried out by a vehicle in an overseas jurisdiction which enjoys the benefit of relief under a double tax treaty with the UK. Legislation including what is now TIOPA 2010 s 130 was introduced in FA 2008 to prevent UK resident persons taking advantage of this kind of arrangement.
Where the ultimate economic ownership of the trading vehicle is overseas there is logic in choosing to use a company situated in an appropriate treaty jurisdiction ...
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Michael Thomas (Pump Court Tax Chambers) looks at the rules introduced in the recent Budget intended to ensure that profits from a trade dealing in or developing UK land are always chargeable to UK corporation tax or income tax.
For many years some taxpayers have sought to shield profits from trading and developing UK land. Their approach is to have the relevant activities carried out by a vehicle in an overseas jurisdiction which enjoys the benefit of relief under a double tax treaty with the UK. Legislation including what is now TIOPA 2010 s 130 was introduced in FA 2008 to prevent UK resident persons taking advantage of this kind of arrangement.
Where the ultimate economic ownership of the trading vehicle is overseas there is logic in choosing to use a company situated in an appropriate treaty jurisdiction ...
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:
