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. Where individuals are non-UK resident or UK resident but non-UK domiciled (non-dom), it has been common practice to hold UK property indirectly through offshore structures for tax, probate and privacy reasons. To increase the tax intake on UK property held through structures and to increase transparency, the government has introduced a wide range of measures aimed at those holding UK real property indirectly.

This subtopic focuses mainly on the taxation of residential property acquired for personal use by or on behalf of non-resident and UK resident non-doms, but also provides introductory guidance on investment and commercial property taxes.

Taxes on buying, holding and disposing of UK property

To tackle avoidance various new and revised taxes on buying, holding and disposing of UK property have been introduced or announced since 2011. These measures are outlined below and relate principally to the introduction of the annual tax on enveloped dwellings (ATED) and to further stamp duty land tax (SDLT) and capital gains tax (CGT) charges. The measures

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Latest Private Client News

Question of the week: Where a trust of a life policy otherwise falls within the definition of an 'excluded trust' set out in paragraph 4 of Schedule 3A of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, does it lose that excluded trust status if it opens a non-interest bearing bank account in order to pay insurance premiums for the policy?

This Q&A considers whether a trust of a life policy, which otherwise falls within the definition of an 'excluded trust' as set out in the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, Sch 3A, para 4 loses its excluded trust status if it opens a non-interest bearing bank account to pay insurance premiums for the policy.

Tax update spring 2025—Tax analysis

Tax analysis: On 28 April 2025, the government announced a package of technical tax policy proposals aimed at simplifying and reforming the tax system and improving tax administration. These announcements included the publication of draft legislation, new consultations, various technical papers and responses to consultations, as well as updates on previously announced measures together with new initiatives.

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Tax analysis: In Refinitiv Ltd v HMRC, the First-tier Tax Tribunal (FTT) directed that HMRC issue closure notices in respect of enquiries into 2018 corporation tax returns, averring that it had not met the burden of proof required for the enquiries to be kept open.

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Private Client analysis: The High Court has resolved a dispute between two executors over the funeral arrangements for their father, a devout Hindu. In a sensible and sensitive decision which reviewed and applied settled principles, the judge (HHJ Paul Matthews) considered the various factors which favoured cremation in England over burial in India. These included the wishes of the deceased, the views of his family, the strength of his connections to the UK and India, and practicalities such as cost and delay. While the relevant factors and their relative weight will inevitably be fact-sensitive, similar factors are likely to recur in many such cases. What is clear is that no single factor (in particular, the deceased’s own wishes) will necessarily be conclusive, so that the court must weigh all relevant factors with care. Written by Kyle Bonnell, barrister at XXIV Old Buildings.