Dominic Lawrance, Helen Coward and Catrin Harrison (Charles Russell Speechlys) analyse the recent overhaul of the rules on land disposals.
A time of change
UK residential property held by non-residents has been a particular target of tax changes in recent years. In 2012 a punitive 15% SDLT rate was introduced for most corporate purchases of UK residential property. This was followed in 2013 by the introduction of ATED an annual wealth tax on UK dwellings held by companies.
Subsequent legislative changes brought in ATED-related CGT and then non-resident CGT (NRCGT) both of which generally subjected non-UK residents to tax on gains realised on direct disposals of UK residential property. There were certain let-outs; for example for disposals of such land by non-resident companies that were diversely held.
A further major change in relation...
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Dominic Lawrance, Helen Coward and Catrin Harrison (Charles Russell Speechlys) analyse the recent overhaul of the rules on land disposals.
A time of change
UK residential property held by non-residents has been a particular target of tax changes in recent years. In 2012 a punitive 15% SDLT rate was introduced for most corporate purchases of UK residential property. This was followed in 2013 by the introduction of ATED an annual wealth tax on UK dwellings held by companies.
Subsequent legislative changes brought in ATED-related CGT and then non-resident CGT (NRCGT) both of which generally subjected non-UK residents to tax on gains realised on direct disposals of UK residential property. There were certain let-outs; for example for disposals of such land by non-resident companies that were diversely held.
A further major change in relation...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
