Claire Weeks and Dominic Condé-Cole (Maurice Turnor Gardner) explain why it’s now a very good time to consider de-enveloping in order to mitigate the increasing double tax costs.
Background
Holding UK residential property through a non-UK company has historically offered a number of UK tax advantages depending on the residence and domicile status of the shareholder. The focus of this article is individuals who are both non-UK tax resident and non-UK domiciled. The period since 2012 has seen a gradual erosion of these benefits and an increase in the tax exposure of corporate holding structures for such individuals.
1. SDLT on property purchases
FA 2012 introduced a 15% rate of SDLT for certain non-natural persons purchasing residential property for consideration exceeding £2m (with the threshold reduced to £500 000 in 2014). This was a significant disincentive for those wishing to purchase a property in the name...
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:
Claire Weeks and Dominic Condé-Cole (Maurice Turnor Gardner) explain why it’s now a very good time to consider de-enveloping in order to mitigate the increasing double tax costs.
Background
Holding UK residential property through a non-UK company has historically offered a number of UK tax advantages depending on the residence and domicile status of the shareholder. The focus of this article is individuals who are both non-UK tax resident and non-UK domiciled. The period since 2012 has seen a gradual erosion of these benefits and an increase in the tax exposure of corporate holding structures for such individuals.
1. SDLT on property purchases
FA 2012 introduced a 15% rate of SDLT for certain non-natural persons purchasing residential property for consideration exceeding £2m (with the threshold reduced to £500 000 in 2014). This was a significant disincentive for those wishing to purchase a property in the name...
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:
