Capital Letters — April 2014: the great CGT land-grab

Welcome to the first edition of Capital Letters — the e-bulletin of Stephenson Harwood’s private wealth team. Every month, we will bring you news of developments in tax and private client law that will be of interest to high-net-worth individuals and their advisers.

In March, HM Treasury issued a consultation document entitled ‘Implementing a capital gains tax (CGT) charge on non-residents’. While we were expecting this con-doc — following the announcement in the Budget — we were not quite ready for its contents. The real shock was the proposed wholesale extension of CGT to all non-resident owners of residential property in the UK. We were led to believe from the Budget that the proposal was to simply extend CGT to those properties thatwere used for personal occupation by their non-resident owners — along the lines of the annual tax on enveloped dwellings (ATED) rules that were introduced last year.

However, it turns out that the government believes that any disposal of residential UK property should be charged to CGT, regardless of how the property is used or the legal personality of the owner. If these rules are enacted then it makes rather a non-sense of the ATED-related gains rules and creates a three-tier CGT cake of the most unappetising kind…

Click on the link below to read the rest of the Stephenson Harwood briefing.

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