The draft legislation taxing non-residents on gains from UK land gives funds and their investors much to think about. Emily Clark and Jonathan Woodall (Travers Smith) consider the key points.
As announced at Autumn Budget 2017 non-UK residents will from April 2019 be subject to UK tax on gains arising from disposals of all types of UK land and interests in UK property rich entities. This significantly expands the current non-resident capital gains tax (NRCGT) regime which applies to UK residential property gains only and exempts (on claim) diversely held companies and widely marketed funds.
The draft legislation implementing this measure (and rewriting the existing NRCGT rules) was published in July 2018 but it did not contain any bespoke provisions for property funds. Instead HMRC set out some high level proposals and acknowledged that further work was required in this area in light of issues raised...
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The draft legislation taxing non-residents on gains from UK land gives funds and their investors much to think about. Emily Clark and Jonathan Woodall (Travers Smith) consider the key points.
As announced at Autumn Budget 2017 non-UK residents will from April 2019 be subject to UK tax on gains arising from disposals of all types of UK land and interests in UK property rich entities. This significantly expands the current non-resident capital gains tax (NRCGT) regime which applies to UK residential property gains only and exempts (on claim) diversely held companies and widely marketed funds.
The draft legislation implementing this measure (and rewriting the existing NRCGT rules) was published in July 2018 but it did not contain any bespoke provisions for property funds. Instead HMRC set out some high level proposals and acknowledged that further work was required in this area in light of issues raised...
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:
