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Draft Finance Bill 2019: the private client perspective

Andrew Goldstone and Natalie Quail (Mishcon de Reya) consider the eagerly anticipated measures that have been published.
 

Non-resident’s CGT to include gains on commercial property disposals

This measure was announced at Autumn Budget 2017 and a consultation ran from 22 November 2017 to 16 February 2018.

Finance Bill 2019 will include legislation to bring gains accruing to non-UK residents on disposals of all UK real property within the scope of UK CGT. The material effect of this measure (effective from 6 April 2019) will be that non-residents’ CGT will be extended to disposals of commercial property. Non-residents who sell shares in a company that derives its value from UK property will also have to pay CGT.

The government has stated that TCGA 1992 Part 1 and Part 2 Chapters 5 6 and 7 will be re-written to accommodate the taxation of non-UK residents making disposals of...

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