UK real property

UK real property

UK real property is often purchased by or for international private clients for personal use, investment or trading purposes. Prior to 6 April 2025, where individuals were non-UK resident or UK resident but non-UK domiciled (non-dom), it had been common practice to hold UK property indirectly through offshore structures for tax, probate and privacy reasons. To increase the tax take on UK property held through structures and to increase transparency, the government introduced a wide range of measures aimed at those holding UK real property indirectly.

On 6 April 2025, the remittance basis, which had been available to non-doms as a means of sheltering non-UK income and gains from UK taxation, was abolished. In addition, domicile as the connecting factor for inheritance tax (IHT) purposes was replaced by the concept of ‘long-term UK residence’. For more information on these events, see Practice Notes: The abolition of the remittance basis of taxation from 2025–26 and A new residence-based regime for IHT from 2025–26.

This subtopic focuses mainly on the taxation of residential property acquired for personal use by or on behalf of non-resident

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This Q&A considers whether, if a client has received a gift of funds from his aunt. His brother has received the same amount. The brothers have agreed between themselves to use the funds for her care if she requires it and they have drawn up a Deed to document this. Will the terms of the Deed override their Wills (their Wills leave their respective estates to their wives).