Non-residents and tax on chargeable gains from 6 April 2019—gains and UK immovable property
Non-residents and tax on chargeable gains from 6 April 2019—gains and UK immovable property

The following Private Client practice note provides comprehensive and up to date legal information covering:

  • Non-residents and tax on chargeable gains from 6 April 2019—gains and UK immovable property
  • Background
  • Basic scope of the rules
  • What is an interest in UK land?
  • Direct disposals of UK real property by non-residents
  • Disposals of UK non-residential property
  • Disposals of UK residential property
  • Indirect disposals of UK real property by non-UK resident persons
  • Indirect disposals of UK non-residential and residential property
  • Indirect disposals—75% property richness test
  • More...

FORTHCOMING CHANGE relating to property rich collective investment vehicles and certain investors: HMRC consulted until 16 December 2020 on draft regulations that will amend provisions in Finance Act 2019 relating to collective investment vehicles (CIVs). The draft regulations provide for non-UK resident life assurance companies and non-UK resident, non-UK property rich CIVs, with less than a 10% interest in UK property rich CIVs (wherever resident), to be treated as not holding a substantial indirect interest in the CIV (subject to certain conditions). The aim is to remove disproportionate administrative burdens for such investors. This change is to have retrospective effect from 6 April 2019. The draft regulations also contain provisions to correct minor errors in the legislation without changing the way the relevant rules operate. These provisions are to have effect from the commencement date of the regulations (expected to be in April 2021).

Background

On 6 July 2018, the government published draft legislation to be included in Finance Bill 2019 (formally the Finance (No 3) Bill 2017–19, but also known as Finance Bill 2018–19) (FB 2019). The draft legislation was subject to public consultation until 31 August 2018. It was introduced in revised form to Parliament as part of FB 2019 on 7 November 2018, following Budget 2018 on 29 October 2018. Following minor amendments at committee stages, the Finance Act 2019 (FA 2019) received

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