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UK CGT for non-residents:‘a return to offshore companies’?

By Andrew Goldstone & Jonathan Legg, Mishcon de Reya

There has been recent speculation that non-residents might have to start paying UK CGT on their UK property. The chancellor will give his Autumn Statement on 5 December and any changes are likely to be announced then ...

When might the changes take effect?

To impose a CGT charge on historic gains would be considered grossly unfair and would effectively be a retrospective tax change. Whilst not impossible we think that is unlikely. If only future gains are to be taxed there is no great rush and it seems likely the government would introduce the new CGT charge for disposals after 5 April 2014 with a consultation period before then. However if the changes are to apply to all historic gains since acquisition the new rules are more likely to take effect from the day of...

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