- Draft Finance Bill 2019—any surprises for non-resident property owners?
- Are there any surprises on the taxation of gains on UK immovable property in the draft FB 2019?
- Collective investment vehicles
- Transparent offshore funds
- Special funds regime
- Definition of ‘offshore fund’
- Disapplication of the 25% requirement for collective investment schemes
- Non-close test
- Joint ventures
- Stamp duty land tax (SDLT)
- Other surprises
- Has the draft legislation provided clarity in any other areas?
- Are you seeing or are you expecting any changes to existing property structures and new UK property acquisitions as a result of the proposed changes?
Tax analysis: The draft Finance Bill 2019 (Draft FB 2019), published on 6 July 2018, includes provisions for taxing direct and indirect gains made by non-residents on UK immovable property and for bringing non-resident companies chargeable to income tax within corporation tax. Cathryn Vanderspar, partner and head of London tax at Eversheds Sutherland, discusses the draft legislation on the treatment of gains that follows an earlier consultation.
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