A New Regime for UK Residential Property Ownership

The long awaited draft Finance Bill for 2013 has finally been published, providing further information as to the way UK residential properties valued at over £2 million will be taxed from April 2013 in the form of an increase in stamp duty (SDLT), the proposed annual charge (now called the Annual Residential Property Tax) and the extension of Capital Gains Tax on a disposal.

The aim of this note is to highlight how Appleby may assist you and your clients in relation to HMRC’s changes to the taxation of UK residential properties valued at over £2 million that are held in offshore structures that you administer.

Typically investment into such high-value UK residential properties has involved the use of an offshore holding company/offshore trust. This simple structure has avoided many forms of UK taxation, other than normal SDLT on purchase and the usual local property rates and taxes. This has changed in a way that will have far-reaching impact on the holding and purchase of UK residential property valued at over £2 million after April 2013…

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