The Resource The UK's attack on offshore corporate ownership of UK residential property

The UK's attack on offshore corporate ownership of UK residential property

Label
The UK's attack on offshore corporate ownership of UK residential property
Title
The UK's attack on offshore corporate ownership of UK residential property
Creator
Subject
Language
eng
Summary
The chief advantage of using an offshore company on behalf of non-UK-domiciled individuals to acquire UK residential property has been protection from UK inheritance tax (IHT) on the value of the UK property owned by the offshore company. This advantage applies for so long as the individual shareholder or ultimate beneficial owner of the offshore company remains non-UK-domiciled. For UK resident but non-UK-domiciled individuals, long-term residence in the UK leads to a statutory "deemed domicile" status for IHT purposes (in which case the offshore company shares come into charge to UK inheritance tax). The maximum period of time during which non-UK-domiciled status for IHT purposes can be maintained as a UK resident is currently 16 years from the date of arrival in the UK. However, for UK income tax and capital gains tax (CGT) purposes, non-UK-domiciled status (which confers the benefit of the famous remittance basis) has been able to be preserved throughout several decades of UK residence. However, following Chancellor Osborne's budget statement on 8 July 2015 planning in this area will need to be revised. Nowadays there are tax penalties associated with offshore corporate ownership of UK residential property which are set out in this article. All the penalties are linked to "the annual tax on enveloped dwellings" (ATED). In effect the penalties are threefold, being an enhanced rate of stamp duty land tax, an annual tax, and an "exit" tax when the property is disposed of by the offshore company if such disposal results in the offshore company realising capital gains. The offshore company is not the only "envelope" that is penalised in this way. So too are partnerships consisting of even one corporate partner, and collective investment schemes
Citation source
In: Offshore Investment. - Belfast. - (2015), no. 258 ; p. 15-16
http://library.link/vocab/creatorName
Palmer, M
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • offshore company
  • immovable property
  • inheritance tax
  • capital gains tax
  • penalties
  • annual tax on enveloped dwellings
  • trust
Label
The UK's attack on offshore corporate ownership of UK residential property
Instantiates
Publication
Label
The UK's attack on offshore corporate ownership of UK residential property
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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