Matthew Shayle (Burges Salmon) answers a query on the post-April 2017 benefits of a holding structure governing the ownership of a London property lived in by a non-UK domiciled individual.
Question
CZ is a UK resident non-UK domiciled individual who has been resident in the UK since 2000. He lives in his Pimlico pied-à-terre (bought in 2012 for £2.2m) which is owned directly by CZ (BVI) Ltd which in turn is held by the trustees of a non-UK resident trust established by CZ’s mother in 1990. CZ is wondering whether the holding structure is really going to provide any benefit after April 2017 and is considering ‘de-enveloping’ before that date. What should CZ do?
Answer
CZ has no doubt been forced to think about the tax position of the property on a regular basis since 2013: the...
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Matthew Shayle (Burges Salmon) answers a query on the post-April 2017 benefits of a holding structure governing the ownership of a London property lived in by a non-UK domiciled individual.
Question
CZ is a UK resident non-UK domiciled individual who has been resident in the UK since 2000. He lives in his Pimlico pied-à-terre (bought in 2012 for £2.2m) which is owned directly by CZ (BVI) Ltd which in turn is held by the trustees of a non-UK resident trust established by CZ’s mother in 1990. CZ is wondering whether the holding structure is really going to provide any benefit after April 2017 and is considering ‘de-enveloping’ before that date. What should CZ do?
Answer
CZ has no doubt been forced to think about the tax position of the property on a regular basis since 2013: 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:
