The new era non-residents and UK residential property
|
|
- Ethan Aubrey Simon
- 5 years ago
- Views:
Transcription
1 The new era non-residents and UK residential property Emma Chamberlain Pump Court Tax Chambers 16 Bedford Row London WC1R 4EF Tel October 2015 STEP
2 Overview A mess contradictory objectives Drive to discourage enveloping BUT failure to understand why people envelope EU constraints due to free movement of capital Further change forthcoming Only residential property targeted not commercial can this policy be justified? 2
3 Main changes affecting non-residents holding residential property Over the past three years the government has introduced: new taxes on high value residential property held by companies (whether UK or offshore): ATED and ATEDrelated capital gains tax; inheritance tax restrictions on excluded property where borrowing is secured on UK property; higher SDLT on high value residential properties; capital gains tax on all residential property held by nonresidents; A new inheritance tax charge from April 2017 on all residential property owned by excluded property trusts or foreign doms; BUT commercial property is largely unaffected! 3
4 Main changes affecting non-residents holding residential property We cover: Acquisition Retention including death Disposal The position on acquisition by NR of property worth nearly 5m 4
5 The purchase - stamp duty land tax (SDLT) SDLT is paid by the buyer on the purchase price. The rates of SDLT have been increasing anyway in recent years but from 4 December 2014 the actual and effective rates changed significantly. Broadly, for purchases NOT made through a company, the position is as follows: Before 4 December 2014 From 4 December 2014 Purchase price Rate % Charged on total purchase price 0 125, , , , , , , , , ,000 5 Purchase price Rate % Charged as part of purchase price within each band 500,000 1,000, ,000 1,500, ,000,000 2,000,000 5 > 1,500, > 2,000,
6 The purchase - stamp duty land tax (SDLT) The method of calculating SDLT has also changed but only to residential properties. Previously, if the purchase price fell into a particular band (say between 1m and 2m) a single rate (5% in this case) applied to the whole purchase price. Now each part of the purchase price in a particular band is taxed at the relevant rate. The overall impact is that SDLT has increased for the purchase of properties in excess of 1.125m and the most expensive UK properties will now incur SDLT at an average rate very close to 12% - similar to 15% for enveloped properties 6
7 Purchase and companies - SDLT Since 21 March 2012, 15% SDLT has been charged on companies acquiring high value property. No banding. Schedule 4A FA 2003 From 20 March 2014 the threshold was lowered so that residential properties acquired for over 500,000 are caught. Where the 15% rate applies, it applies to the entire purchase price (i.e. it is not banded). Catches gifts of property to connected companies FA 2003 s53 transaction is deemed to take place at market value Where an ATED relief applies (eg where the property is rented out), the company may pay SDLT at the normal rates as long as the property qualifies for relief throughout the first three years of ownership. If it fails to qualify throughout the period, the difference between the punitive 15% and the SDLT actually paid is clawed back. HMRC may well request EVIDENCE of use 7
8 Retaining the property inheritance tax: new changes To avoid inheritance tax, non-resident foreign doms often hold UK property, especially let property, through corporate vehicles. This resites the property and means it is excluded property. Technical brief July 2015 announced a new inheritance tax charge from April If UK residential property is held through a foreign newco or partnership and would otherwise be excluded property because it is owned by a foreign dom individual or trust then for chargeable events after April 2017 inheritance tax will now be imposed. So on any outright gift of newco inheritance tax will be payable if individual dies within 7 years; gifts into or out of trust after April 2017 entry and exit charges payable. Watch reservation of benefit provisions where settlor is non-resident and foreign dom and benefits from a trust that holds UK residential property through a corporate vehicle. On deaths after April 2017 inheritance tax could be payable. Exclude settlor before Ten year charges will arise on trusts holding UK property through newcos. 8
9 Retaining the property inheritance tax Applies to all residential property of any value and whether or not let. Not quoted companies Aims to catch non-residents buying UK residential property through corporate vehicles. Many questions on new proposal remain unanswered. Art and commercial property owned in a foreign newco are unaffected and the technical brief makes it clear there are no proposals to extend inheritance tax more generally to UK property held in foreign companies which are excluded property FA Consultation document/draft legislation next year 9
10 Retaining the property - ATED ATED has applied since 1 April 2013 to high value properties held by companies, partnerships with a corporate partner and collective investment schemes. Residence of company is irrelevant and includes UK companies High value refers to properties over 2m but, from 1 April 2015, properties over 1m will be included and from 1 April 2016 properties over 500,000 will also be included. Exemption e.g. if property let out but reporting still required In addition, from 1 April 2015, the rates of ATED increased by 50%, as follows (s70 FA 2015): 10
11 Retaining the property - ATED Property value ATED 1 April March 1 April March ,000 1,000, ( 3500 from 1 April 2016) 1,000,000 2,000, ,000 2,000,000 5,000,000 15,400 23,350 5,000,000 10,000,000 35,900 54,450 10,000,000 71, ,050 20,000,000 There are exemptions and reliefs from ATED. The reliefs > 20,000, , ,200 11
12 Selling the property ATED-related CGT Since 6 April 2013, ATED-related CGT has applied on the disposal of high value properties by companies within ATED regime - only the increase in value after 5 April 2013 is subject to ATED-related CGT. Rate is 28%. No indexation Applies to companies resident in the UK and abroad. To the extent ATED reliefs such as letting relief apply then the gain on disposal will also be relieved from ATED-related capital gains tax FA ATED-related CGT extended to property worth 1m for disposals from 6 April 2015 and to property worth 500K from April 2016 Takes priority over NR capital gains tax 12
13 Selling the property non-residents CGT Legislation found in FA 2015 Schedules 7 and 9. From 6 April 2015, CGT will potentially apply to all non-residents on the disposal of ANY residential property interest. i.e. a dwelling S14B(1) TCGA Includes gifts except to spouse Letting irrelevant so the scope of the tax is much wider than ATED. Where properties exposed to the NR CGT charge were held before 6 April 2015, they will be rebased (tax-free) to that date, thereby removing the earlier gains from the new charge. Taxpayers can opt to disapply rebasing but it is the default option. Rates will be: 18% or 28% for individuals (depending on total UK income and gains), no indexation. Possible PPR 28% for trustees (possible PPR) and PRs without indexation and 20% for companies (with indexation) no PPR. 13
14 What land does NR CGT apply to? Any building which is used or suitable for dwelling and any garden and grounds regardless of size, use, value or the status of the disponer Exclusions for institutions including schools, hospices, prisons, care homes and purpose built student accommodation managed or controlled by the university and with at least 15 bedrooms, occupied by students for 165+ days pa Dwelling which is temporarily unsuitable for use as a dwelling continues to be treated as a dwelling unless accidental or involuntary damage renders it unsuitable for use for at least 90 consecutive days. Dwelling ceases to exist if it is demolished to ground level Not a dwelling if it is undergoing works to convert it to something else authorised by planning permission which can be given retrospectively What if the property has been a non-residential dwelling for part of the period of ownership since April 2015 or the property is or has been mixed use, i.e. part residential and part not? In the case of mixed use a just and reasonable apportionment is required In the case of change of use - time apportionment 14
15 Who does NR CGT apply to individuals Any non-resident individual TCGA 1992 s14b Condition A Any resident individual if the disposal takes place in the overseas part of a split year Condition B Annual exemption applies Rates are normal capital gains tax rates 18% and 28% Availability of 18% rate depends on whether the individual has taxable UK source income. UK dividends and income are excluded in calculating that rate; UK rental income is included PPR available even for non-residents if appropriate election made 15
16 Who does NR CGT apply to partnerships and trusts Normal look through applies to partnerships TCGA 1992 s59 Trusts the charge applies to non-resident trusts Normal trust residence rules apply Rate is 28%. No indexation. Gain that is subject to NR capital gains tax is outside ss86 and
17 Who does NR CGT apply to companies All NR companies are prima facie within the charge. Charge is capital gains tax but the rate of tax is corporation tax rates. 20% Imposing a higher rate on NR companies than UK companies would not be EU compliant Calculated as for corporation tax so indexation applies. ATED-related capital gains tax takes priority Inter group disposals ignored A company can claim exemption on disposal if diversely held (i.e. not close) or an OEIC or unit trust which meets the widely marketed condition or a life company Quoted companies are not excluded from the NRCGT if closely held TAAR applies 17
18 Property held on or after 6 April 2015 computing the gain Although the default method is to assume a deemed acquisition at market value on 6 April 2015 (Sch 4ZZB para 6) note that if NR individual or trust becomes UK resident prior to sale there is no rebasing although rebasing becomes available again if the individual becomes NR before disposal. Advice may be to rebase property before a NR arrives here! 18
19 HMRC FAQ s 18 March 2015 Q20 I bought a UK residential property in 2001 whilst I was living abroad. I moved to the UK in December 2015 and sold the property at a gain in March Can I rebase to 5 April 2015? A20 No. UK residents are unaffected by the changes and will be subject to CGT in the normal way i.e. chargeable on the full gain less any reliefs due along with the CG annual exemption. 19
20 Property held on 6 April 2015 computing the NR gain Property held on 5 April 2015 default rule likely to apply 3 computational methods (taxpayer s choice when he files the NR return): (a) Rebasing as at 5 April 2015 (automatic default); (b) No rebasing (use where the property has fallen in value); and (c) Straight line apportionment (useful where a property increases in value disproportionately after 5 April 2015) No relief from the charge for letting the property (c.f. ATED) Compliance cost: NRCGT form on disposal even if no tax (30 days!) NRCGT losses only against gains of the same type (unless UK res) For trusts, NRCGT paid by trustees reduces stockpiled gains pool April 2015 valuation obtained now or when filing? 20
21 PPR position from 6 April 2015 To qualify, an individual or his spouse now has to be resident in the territory where the house is or singly or together the individual/spouse must meet the day count test spend 90 midnights in that house or another house in the same territory Residence in the UK is determined by the Statutory Residence Test (SRT) Not a one-off test at sale. For every period post April 2015 that the new rules are not met PPR will be lost (subject to the final 18 months applying). Keep careful records. Changes only apply from 2015/16. In determining relief for periods prior to 6 April 2015, the new rules are ignored 21
22 Property held on 6 April 2015 PPR s222b TCGA NR can make a PPR election: no two year time limit and can be backdated indefinitely. Make election at the time of disposal in NRCGT return Right to make a PPR election cannot be restricted to UK or EU residents as this would be a restriction on free movement of capital Prior election when becoming UK resident can be cancelled unless another property elected has been disposed of If a person owns a house on arrival in the UK he cannot elect from scratch unless the two year clock can be started again eg. he acquires another residential property he occupies or a let property ceases to be let and he occupies it as a residence Keep careful records of occupation each year How do you prove the position? Last 18 months ownership applies if property has been main residence for any part of the period of ownership even before
23 Property held on 6 April 2015 PRR FAQs Q11 I lived in the property for 20 years before leaving the UK in 2010 and had met all the conditions for PRR up to that date. Does this mean if I sell the property by 5 October 2016 there will be no capital gains tax liability? Answer Yes. If you can identify a time period prior to 6 April 2015 that the property qualified for PRR then final period relief will be available i.e. the last 18 months of ownership will be eligible for relief 23
24 Administration of NRCGT NRCGT return must be filed within 30 days of completion on a form prescribed by HMRC TMA 1970 s12zb This is the case even if end of year tax return filed. Self-assessment: NRCGT return must be accompanied by an advance selfassessment. This is not required if the disponer has already been required by HMRC to deliver a tax return for the current or the prior tax year. S12ZG Advance self-assessment also not required if the disponer has delivered an ATED return If the NRCGT return is accompanied by a self-assessment, the capital gains tax is payable on filing TMA 1970 s59aa Otherwise payable by 31 January following the end of the tax year No burden on solicitors to deduct withholding tax from sale proceeds But note all non-residents must file a NRCGT return within 30 days whether or not within self-assessment and whether or not there is a gain. Intended to raise 70m by 2018/19. 24
25 Current and future position for companies SD / SDLT IHT IT 12% - 15% - still no SDLT on sale of shares 40% - no protection from Apr 2017 and new deductibility of debt rules (s.162a) 20% UK withholding if let / shadow director if occupy and UK res / reduce IT on rent by borrowing non-uk resident CGT Less s.13 TCGA risk if UK resident (EU), otherwise nil no tax on sale of shares ATED 218,200 per year + CPI ( 20m+ houses) N.B. applies to UK companies too. o/s company ATED-CGT 28% on gain since purchase or 1 April 2013 No tax on sale of shares NRCGT GAAR Privacy Succession 20% for gains after 5 April 2015 No tax on sale of shares n/a but consider debt Less but some however beneficial ownership register Law of domicile for shares foreign will UK residential 25
26 DISCLAIMER The ideas contained in these slides should not be relied on by any person in any particular case without taking further specific advice. No liability is accepted to anyone who acts or omits to act in reliance on the content of these slides tel Pump Court Tax Chambers 26
The taxation of UK residential property: changes and proposals
The taxation of UK residential property: changes and proposals Surprise measures to increase the scope of certain taxes on higher value residential property acquired by and/or held through corporate envelopes
More informationTaxing UK residential property. Presentation to the STEP conferences, Autumn 2017
Taxing UK residential property Presentation to the STEP conferences, Autumn 2017 OWNING A RESIDENTIAL PROPERTY WHICH TAXES? SDLT Income Tax Capital Gains Tax/Non-resident capital gains tax ATED and ATED-related
More informationUK Residential Property Update. Accounting & Tax. trusted to deliver...
UK Residential Property Update Accounting & Tax trusted to deliver... UK Residential Property Update The below provides a general overview of the key considerations for individual, trust or corporate ownership
More informationCapital gains for nonresidents. legislation released
Finance Bill 2015 Capital gains for nonresidents - draft tax legislation released Introduction On 10 December 2014 the UK Government released draft legislation on the extended capital gains tax (CGT) charge
More informationOffshore companies owning UK residential property
Offshore companies owning UK residential property New UK tax considerations in 2018 Introduction There has been a long history of acquisition of UK residential property via offshore companies by non-uk
More informationWelcome. UK Tax Update Jason Laity. 7 December, 2016
Welcome UK Tax Update Jason Laity 7 December, 2016 Agenda 8:30-8:35 Introduction Jason Laity 8:35-8:55 UK residential property Jason Laity 8:55-9:25 Long term UK residents, including rebasing, mixed funds,
More informationUK PROPERTY TAXES COMMERCIAL AND RESIDENTIAL UPDATE JUNE 2018
UK PROPERTY TAXES COMMERCIAL AND RESIDENTIAL UPDATE JUNE 2018 TIMELINE OF TAX CHANGES The last few years have seen a transformation in the landscape for the taxation of property ownership in the UK with
More informationPlenary 3 CGT Update and Property Structuring
Plenary 3 CGT Update and Property Structuring John Barnett CTA (Fellow) TEP Partner, Burges Salmon Topics CGT Update Residential Property Structures ATED, SDLT, CGT and IHT Conventional UK planning for
More information15 Old Square, Lincoln s Inn London WC2A 3UE. Amanda Hardy QC
15 Old Square, Lincoln s Inn London WC2A 3UE taxchambers@15oldsquare.co.uk www.taxchambers.com Amanda Hardy QC Update on draft clauses HMRC Stakeholder Meetings The Legislation excluded property The two
More informationPROJECT TITLE UK PROPERTY TAXES UPDATE
PROJECT TITLE UK PROPERTY TAXES UPDATE 2017 TIMELINE OF TAX CHANGES The last few years have seen a transformation in the landscape for the taxation of property ownership in the UK with further changes
More informationa building which is used, or suitable for use as a dwelling a building which is in the process of being constructed or adapted for use as a dwelling.
Briefing Note High Value Residential Properties the new taxes In its drive to tackle tax avoidance the Government is introducing three new measures designed to discourage the use of companies and other
More informationSummary of UK tax changes coming into force from 6 April 2017
Summary of UK tax changes coming into force from 6 April 2017 In the Summer Budget 2015 it was announced that there would be significant changes to the way those who were not domiciled in the UK and living
More informationOctober. Doing property business in the UK
October 2017 Doing property business in the UK 0 F o r w a r d This booklet has been prepared for the use of clients, partners and staff of Menzies LLP. It is designed to give some general information
More informationBARNES ROFFE LLP TAX STRATEGIES FOR PROPERTY INVESTORS
BARNES ROFFE LLP TAX STRATEGIES FOR PROPERTY INVESTORS Keith Mason / Paul Hughes 27 th September 2018 Seminar Coverage Residential Buying Renting Selling Keeping Changing Commercial Buying Renting Selling
More informationCHANGES FOR NON-UK DOMICILES: DEEMED DOMICILE FROM 2017
Harriet Brown Old Square Tax Chambers 15 Old Square, Lincoln s Inn, London WC2A 3UE T: (020)7242 2744 F: (020)7831 8095 harrietbrown@15oldsquare.co.uk CHANGES FOR NON-UK DOMICILES: DEEMED DOMICILE FROM
More informationForeign Tax Alert Stay informed of new developments
Singapore Tax 8 December 2014 Foreign Tax Alert Stay informed of new developments Capital Gains Tax and UK residential property On 27 November 2014 the UK government published its response to the consultation
More informationYEAR END TAX PLANNING
2015/16 YEAR END TAX PLANNING 2015/16 Introduction Income Tax Tax-efficient Investments Social Investment Tax Relief Residential Landlords Restrictions on Mortgage Interest Dividend Tax Credit Pensions
More informationTaxation of individuals during a divorce can be potentially complicated by one or both of the parties being classified as non UK resident.
Cross border divorce 1 August 2017 Meg Saksida considers the tax aspects of cross border expatriate divorce What is the issue? Taxation of individuals during a divorce can be potentially complicated by
More informationPrivate Client Briefing
chartered accountants & tax advisers Private Client Briefing Spring 2018 Articles in this edition Annual planning opportunites Residential landlords restrictions on mortgage interest Making tax digital
More informationAPRIL 2017 UK TAX CHANGES: BE PREPARED
APRIL 2017 UK TAX CHANGES: BE PREPARED MARCH 2017 The UK Government will radically revise the UK tax regime for long-term resident but non-domiciled individuals from 6 April 2017. These plans have been
More informationPrivate Wealth. Reforms to the Taxation of UK Residential Property
Private Wealth Reforms to the Taxation of UK Residential Property Introduction The 2015 Summer Budget (8 July 2015) heralded the announcement of fundamental changes to the taxation of non-uk domiciliaries
More informationHMT: Reforms to the taxation of nondomiciles. The Law Society's response November The Law Society. All rights reserved.
HMT: Reforms to the taxation of nondomiciles The Law Society's response November 2015 2015 The Law Society. All rights reserved. 1. The Law Society is the professional body for solicitors in England and
More informationFor Adviser use only Not approved for use with clients. Estate Planning
For Adviser use only Not approved for use with clients Adviser Guide Estate Planning Contents Inheritance tax: Facts and figures 4 Summary of IHT rules 5 Choosing a trust 8 Prudence Inheritance Bond (Discounted
More information3.5.1 Who is affected? Who is not affected? What property finance costs are caught by the new rules?
Contents 1 Introduction... 1 2 Is it property investment or property trading?... 2 2.1 Introduction... 2 2.2 What is the difference in tax treatment?... 2 2.3 Factors that indicate you are trading... 4
More informationThe Law Society's response. January The Law Society. All rights reserved. PERSONAL/IAD-EU /8
HMRC and HM Treasury: Clause 42 and Schedule 13 of the Draft Finance Bill 2017: Inheritance tax on overseas property with value attributable to UK residential property The Law Society's response January
More informationBuy-to-let Landlords
Buy-to-let Landlords This guide examines the tax issues affecting landlords of residential property. The positions of both individual and corporate landlords are considered, as the tax costs and deductions
More informationReform of the Non-Dom Regime - December 2016
19 December 2016 Note: The government finalised the reform of the non-dom regime, and this was part of the second Finance Act of 2017 which gained Royal Assent on 16 November 2017 - please see our technical
More informationIn this summary, we include planning suggestions for: Income Tax. Capital Gains Tax. Inheritance Tax. Pensions. Offshore matters
Year end tax planning 2014/15 The run up to the tax year end on 5 April 2015 is the perfect time to consider tax planning opportunities and to put in place strategies to minimise tax throughout 2015/16.
More informationYear end tax planning guide 2017/2018
Year end tax planning guide 2017/2018 At Handelsbanken Wealth Management we make every effort to advise clients on sensible and appropriate ways to reduce or defer their tax burden in a straight forward
More informationDoing business in the UK. Expansion into the UK - Considerations for US investors. Nick Farmer ACA CTA ATII
Expansion into the UK - Considerations for US investors Nick Farmer ACA CTA ATII London: http://www.youtube.com/watch?v=45etz1xvhs0 Expansion into the UK Doing business in the UK United Kingdom Economy
More informationExpect more from your Tax Partner
Expect more from your Tax Partner IFA London branch meeting Tuesday 5 February 2018 IFA Tax Portal 2 Key property tax changes Caroline Fleet Gabelle SDLT First time buyers relief Conditions for relief
More informationMoving to the UK. A briefing note on the UK tax implications for high net worth individuals
Moving to the UK A briefing note on the UK tax implications for high net worth individuals This briefing note provides an overview of the UK tax issues that high net worth individuals should consider in
More informationTax Issues for landlords of UK residential properties
Tax Issues for landlords of UK residential properties Tax changes affecting rental income from residential lettings There have been many changes to taxation affecting the property letting market recently
More informationCapital gains tax the fundamentals
03/2017 Capital gains tax the fundamentals Capital gains tax (CGT) is charged on capital gains which accrue to a person on the disposal of an asset. CGT is usually assessed on the person who disposed of
More informationAnnual residential property tax and capital gains tax rules for non-natural persons
Annual residential property tax and capital gains tax rules for non-natural persons STEP is the worldwide professional association for practitioners dealing with family inheritance and succession planning.
More informationUK Residential Property. Tax Guide for overseas investors
UK Residential Property Tax Guide for overseas investors January 2018 Contents HW Fisher & Company introduction 4 Our team 5 Tax guide 6 Tax on rental profits 7 Scope of charge 7 Personal allowances 7
More informationMajor taxation changes ahead for non-uk domiciliaries are you prepared for 6 April 2017?
Major taxation changes ahead for non-uk domiciliaries are you prepared for 6 April 2017? February 2017 The current position UK assets UK Income Tax UK CGT UK IHT RND client Non-UK assets Remittance Basis
More informationLandlords Buy-to-let Guide
Buy-to-let: the basics Why become a landlord? You may become a landlord accidentally by inheriting a house, or by retaining a former home when you move house. There is an attractive tax incentive for letting
More informationTAXFAX 2019/20. Private clients. Corporate and business. Property. Employment
TAXFAX 2019/20 TAXFAX 2019/20 Private clients Allowances and reliefs 2 Individuals - Income Tax rates and bands 3 Trusts - Income Tax rates 4 Pension contribution reliefs 4 Capital Gains Tax ( CGT ) 5
More informationLiving abroad the main tax rules
Hebblethwaites Chartered Accountants & Registered Auditors KEY GUIDE Living abroad the main tax rules Planning to leave the UK While the thought of going abroad to work or retire may be exciting, the months
More informationBudget & Finance Bill Update Mike Hayes & Geraint Lewis
Budget & Finance Bill Update - 2013 Mike Hayes & Geraint Lewis Main topics Personal tax allowances & rates Inheritance tax New residence rules Mansion tax Anti-avoidance VAT & other indirect taxes Business
More informationTrust Referencer. Focused Report. for. A life interest arising in a Will. Report includes the following sections
Trust Referencer Focused Report for A life interest arising in a Will Report includes the following sections Outline Inheritance Tax Capital Gains Tax Income Tax This Trust Referencer Report was created
More informationThe Chartered Tax Adviser Examination
The Chartered Tax Adviser Examination Sample Paper Application and Professional Skills Owner Managed Businesses Suggested solutions REPORT TO HORATIO STILES ON 1) THE USE OF SURPLUS FUNDS STILES CONSTRUCTION
More informationTHE 3% SDLT ADDITIONAL CHARGE ON ACQUISITIONS OF RESIDENTIAL PROPERTIES. Patrick Cannon Barrister, Tax Chambers, 15 Old Square
THE 3% SDLT ADDITIONAL CHARGE ON ACQUISITIONS OF RESIDENTIAL PROPERTIES by Patrick Cannon Barrister, Tax Chambers, 15 Old Square Contents Page 1 Background and Context... 1 2 Basics of the 3% Additional
More informationCONTENTS CAPITAL GAINS TAX SIMPLIFICATION CAPITAL GAINS TAX SIMPLIFICATION. Introduction DOMICILE AND RESIDENCE
CONTENTS CAPITAL GAINS TAX SIMPLIFICATION DOMICILE AND RESIDENCE DEEDS OF VARIATION AFTER 8 OCTOBER 2007 CORPORATE INVESTMENT IN LIFE ASSURANCE BONDS CAPITAL GAINS TAX SIMPLIFICATION Draft legislation
More informationRESIDENTIAL PROPERTY AND DIVIDEND CHANGES. Robert Jamieson MA FCA CTA (Fellow) TEP 22 September 2016
RESIDENTIAL PROPERTY AND DIVIDEND CHANGES Robert Jamieson MA FCA CTA (Fellow) TEP 22 September 2016 BUY-TO-LET TAX CHANGES At present, full income tax relief is normally available for interest on loan
More informationUK Real Estate Structuring for Nondomiciled Persons and Solutions for Ownership of Yachts, Private Jets and Art
UK Real Estate Structuring for Nondomiciled Persons and Solutions for Ownership of Yachts, Private Jets and Art IWP Event 5 June 2013 Hugo Jenney Partner, head of tax, Stephenson Harwood LLP hugo.jenney@shlegal.com
More informationBLICK ROTHENBERG UK reporting obligations and UK Taxation of offshore structures
BLICK ROTHENBERG UK reporting obligations and UK Taxation of offshore structures 1. Introduction 2. Headline changes to UK tax 3. IHT Trip Wires for Trustees 4. Touch points for UK reporting 5. UK register
More informationPersonal tax planning: 2018/19
Personal tax planning: 2018/19 Contents Income Tax planning Page 2 Avoiding the 60% band Using allowances and reliefs Loss reliefs Dividend planning Owner-managed businesses Capital Gains Tax planning
More informationRebasing and the changes to the CGT foreign capital losses election - professional bodies Q&As
TAXguide 06/18 Rebasing and the changes to the CGT foreign capital losses election - professional bodies Q&As Version 1 (without HMRC comments see foreword - published 27 March 2018 CONTENTS Foreword QUESTIONS
More informationPersonal tax planning: 2017/18
Personal tax planning: 2017/18 Contents Income tax planning Page 2 Avoiding the 60% band Using allowances and reliefs Loss reliefs Dividend planning Owner managed businesses Equalising income Capital Gains
More informationUK Tax, Trusts & Estates Conference 2018
UK Tax, Trusts & Estates Conference 2018 Succession strategies for owner managers and dealing with shareholder disputes Autumn 2018 Delegate notes and slides to accompany talk given by Peter Rayney, CTA
More informationInvesting tax-efficiently
Investing tax-efficiently Tax is getting more complex The taxation of investments has never been a simple matter. In recent years, it has become more complex as successive governments have chosen to tax
More informationTAX DATA 2018/ BUDGET EDITION 22 NOVEMBER CHANCERY LANE LONDON WC2A 1 LS
TAX DATA 2018/2019 BUDGET EDITION 22 NOVEMBER 2017 22 CHANCERY LANE LONDON WC2A 1 LS TELEPHONE 020 7 680 8100 E-MAIL dw@dixonwilson.co.uk 19 AVENUE DE L OPERA 75001 PARIS TELEPHONE + 33 1 47 03 12 9 0
More informationOwnership of UK dwellings by non-uk domiciliaries
Ownership of UK dwellings by non-uk domiciliaries Changes to the UK tax regime August 2017 Brussels / Du sseldorf / Hamburg / London / Manchester / Milan / Munich / Paris / Rome / Shanghai / Silicon Valley
More informationAnnual Tax on Enveloped Dwellings - the basics
HM Revenue&Customs: Annual Residential Property Tax - the basics 1 Annual Tax on Enveloped Dwellings - the basics Previously called Annual Residential Property Tax, the Annual Tax on Enveloped Dwellings
More informationHow commercial property is taxed
How commercial property is taxed Pay attention to the tax rules before you dip your toe into the commercial property pool Commercial property forms a vital part of the UK economy, providing places for
More informationSafe as houses. A guide to investing in residential property
Safe as houses A guide to investing in residential property Audit / Tax / Advisory Smart decisions. Lasting value. Property investment The old saying an Englishman s home is his castle has been around
More informationTAXFAX 2018/19. Private clients. Corporate and business. Property. Employment
TAXFAX 2018/19 TAXFAX 2018/19 Private clients Allowances and reliefs 2 Individuals - Income Tax rates and bands 3 Trusts - Income Tax rates 4 Pension contribution reliefs 4 Capital Gains Tax ( CGT ) 5
More informationKEY GUIDE. Living abroad the main tax rules
KEY GUIDE Living abroad the main tax rules Planning to leave the UK While the thought of going abroad to work or retire may be exciting, the months before departure may be stressful. Finding somewhere
More informationAdviser guide The Discretionary Gift Trust
This document is for investment professionals only and should not be relied upon by private investors. Adviser guide The Discretionary Gift Trust FundsNetwork Trusts Contents 1 The FundsNetwork Discretionary
More informationYour guide to Investment property tax
Your guide to Investment property tax 2018 19 chartered accountants www.wardwilliams.co.uk Rental Business Whether you hold commercial or private investment properties, Ward Williams can assist you with
More informationTax Planning for Individuals
Tax Planning for Individuals 2018 03333 219 000 advice@bishopfleming.co.uk www.bishopfleming.co.uk Tax Planning for Individuals 2018 Key Updates Income tax 150k 45% 100k- 123k 60% 11,500 Personal Allowance
More informationIncome Tax. Income Tax allowances Personal Allowance (1) 7,475 8,105 N/A
Income Tax Income Tax allowances table Income Tax allowances 2011-12 2012-13 2013-14 Personal Allowance (1) 7,475 8,105 N/A Personal Allowance for people born after 5 April 1948 (1) N/A N/A 9,440 Income
More informationMobility matters The essential UK tax guide for individuals on international assignment abroad
www.pwc.co.uk Mobility matters The essential UK tax guide for individuals on international assignment abroad December 2017 Contents 1 Determining your UK tax liability 1.1 What impact will my overseas
More informationSTEP ADVANCED CERTIFICATE IN UK TAX FOR INTERNATIONAL CLIENTS
STEP ADVANCED CERTIFICATE IN UK TAX FOR INTERNATIONAL CLIENTS Syllabus INTRODUCTION This document contains the detailed syllabus for the STEP Advanced Certificate in UK Tax for International Clients. It
More informationCHAPTER 9 RELEVANT PROPERTY TRUSTS FURTHER ASPECTS
CHAPTER 9 RELEVANT PROPERTY TRUSTS FURTHER ASPECTS In this chapter you will cover further aspects of discretionary trusts, including: Non-relevant property; Excluded property; Trusts becoming discretionary;
More informationCAPITAL GAINS TAX AND THE FAMILY HOME
CAPITAL GAINS TAX AND THE FAMILY HOME Capital Gains Tax and the Family Home The capital gains tax (CGT) exemption for gains made on the sale of your home is one of the most valuable reliefs from which
More informationZurich International Portfolio Bond
Zurich International Portfolio Bond Bare Discounted Gift Trust adviser guide For intermediary use only not for use with your clients. Contents Introduction 3 1. The main benefits of the Bare Discounted
More informationKEY GUIDE. The taxation of investments
KEY GUIDE The taxation of investments Increasing complexity The taxation of investments has never been a simple matter. In recent years it has become more complex as successive governments have chosen
More informationThe Chartered Tax Adviser Examination
The Chartered Tax Adviser Examination November 2017 Suggested solutions Application and Interaction Question 1 - Individuals, Trusts and Estates Application and Interaction November 2017 Question 1 (Individuals,
More informationA GUIDE TO SOME OF THE PRINCIPAL PARTS OF THE OFFSHORE FUNDS RULES - PART II. Michael Jones
A GUIDE TO SOME OF THE PRINCIPAL PARTS OF THE OFFSHORE FUNDS RULES - PART II Introduction Michael Jones The new offshore funds regime, which came into force on 1 December 2009, is now nearly a year old.
More informationYOUR GUIDE. Year End Tax Planning 2016/17
YOUR GUIDE Year End Tax Planning 2016/17 INTRODUCTION As the end of the 2016/17 tax year end approaches, it is important that you take the time to review your financial and tax arrangements, and consider
More informationIn the first of a two-part series, Emma Chamberlain considers the capital gains tax issues arising on divorce
Capital split 1 June 2015 In the first of a two-part series, Emma Chamberlain considers the capital gains tax issues arising on divorce What is the issue? Are payments by foreign domiciliaries to civil
More informationSchedule A1 Inheritance tax on overseas property representing UK residential property Assume in all cases that the companies are close and that the
Schedule A1 Inheritance tax on overseas property representing UK residential property Assume in all cases that the companies are close and that the relevant trust is an excluded property settlement and
More informationB r i e f i n g. 2 9 O c t o b e r
This briefing is directed at professional advisers only and it should not be distributed to, or relied upon by, retail clients. Utmost Wealth Solutions is the brand name used by a number of Utmost companies.
More informationTAX PLANNING CHECKLIST FOR YEAR END
TAX PLANNING CHECKLIST FOR YEAR END 2019 INTRODUCTION As the end of another tax year approaches, now is a good time to consider your financial position and check whether you have taken full advantage of
More informationResidence and domicile and the taxation of overseas income
Residence and domicile and the taxation of overseas income Introduction The liability of individuals to UK tax is affected by their residence and domicile status. Different combinations of residence and
More informationPrivate Client Services
Private Client Services Residential property Charges for non-natural persons March 2013 Residential property: charges for non-natural persons The 2012 Chancellor s Budget contained a number of announcements
More informationDeemed UK Domicile Changes Action Required Now!
BRIEFING NOTE February 2018 Deemed UK Domicile Changes Action Required Now! The principal changes that are effective from 6 April 2017 are as follows: Anyone born in the UK with a UK domicile of origin
More informationInsert image 2017/18. Tax Planning. Bulletin
Insert image 2017/18 Tax Planning Bulletin The medium-term economic outlook is looking distinctly foggy! The weakness of the current Government following last year s General Election has left it short
More informationProperty Tax update. Presented by Robert Maas of CBW Tax. March 2015
Property Tax update Presented by Robert Maas of CBW Tax March 2015 Property Taxes 2014/15 Bloomsbury Professional Introduction Rents Premiums Relief for interest payable Investment or dealing? Tax aspects
More informationTel: E. Stamp Duty Land Tax ("SDLT")
Tel: 0114 218 4000 E. info@tayloremmet.co.uk www.tayloremmet.co.uk Stamp Duty Land Tax ("SDLT") This is a complicated subject, but MUST be addressed by every property purchaser. If you give us incorrect
More informationCapital Gains Summary notes
Capital Gains Summary notes Tax year 6 April 2007 to 5 April 2008 Contents Contacts Please phone: the number printed on page TR 1 of your Return the Helpline on 0845 9000 444 the Orderline on 0845 9000
More informationCustomer Guide Prudence Inheritance Bond
Customer Guide Prudence Inheritance Bond Prudence Inheritance Bond Inheritance tax might be called the voluntary tax as there is much that you can do to reduce it or not pay it at all. Inheritance Tax
More informationAF1/J02 Part 4: Taxation of Trusts (1)
AF1/J02 Part 4: Taxation of Trusts (1) The next three parts will cover the taxation of trusts. Since it is a complex subject each tax, income, capital gains and inheritance tax will be dealt with separately.
More informationACCA P6 Advanced Taxation Question Based Revision - Answers
ACCA P6 Advanced Taxation Question Based Revision - Answers Question One To Tax manager From Tax assistant Date 2/12/2015 Subject: Jeremy and Sarah Turner This memo considers the transfer of investments
More informationREFORM OF THE TAXATION INDIVIDUALS CONSULTATION DOCUMENT OF NON DOMICILED OF 17 JUNE SPEAKER: GILES CLARKE 7 September 2011
REFORM OF THE TAXATION OF NON DOMICILED INDIVIDUALS CONSULTATION DOCUMENT OF 17 JUNE 2011 SPEAKER: GILES CLARKE 7 September 2011!"#$%&%'%()&*+(%&"+,&-%%.&/+0%.&/1&%.,2(%&/"%&+**2(+*)&13&/"%,%&.1/%,&+.4&/"%&+**156+.)#.7&/+$08&.1&(%,61.,#-#$#/)&31(&$1,,&1**+,#1.%4&
More informationT e c h n i c a l S a l e s B r i e f i n g
This briefing is directed at professional advisers only and it should not be distributed to, or relied upon by, retail clients. Utmost Wealth Solutions is the brand name used by a number of Utmost companies.
More informationRESIDENTIAL PROPERTY LETTING A PRIVATE LANDLORD S GUIDE
RESIDENTIAL PROPERTY LETTING A PRIVATE LANDLORD S GUIDE Spring 2017 update Residential property letting provides constant challenges to those who operate within this industry sector. At George Hay, we
More informationEnd of Year Tax planning
End of Year Tax planning 2017-18 As the end of another tax year approaches, we are writing with a summary of tax planning ideas which may be of interest to you. Please call if you would like to discuss
More informationGuide to Residential Property Letting
Guide to Residential Property Letting How is tax calculated and when is it due? The amount on which tax is charged is the net rental income for each tax year (i.e. for each tax year ending on 5 April).
More informationResidential Property Letting Tax Guide
Residential Property Letting Tax Guide Moore Thompson: Creative solutions for all your accountancy needs How is tax calculated and when is it due? The amount on which tax is charged is the net rental income
More informationTAX RATES. for 2015/2016 & ALLOWANCES. simplifying the everyday. for freelancers & contractors
TAX RATES & ALLOWANCES for 2015/2016 for freelancers & contractors simplifying the everyday. Taxes rates & allowances guide Contents Corporation tax 4 Value Added Tax 4 Capital allowances 5 Patent Box
More informationCountdown to 6 April 2017 for non-uk domiciliaries
PRIVATE CLIENT Countdown to 6 April 2017 for non-uk domiciliaries December 2016 In July 2015, the Government announced significant changes to the taxation of resident non-uk domiciled individuals and their
More informationCHAPTER 11 OTHER TRUSTS FOR CHILDREN
CHAPTER 11 OTHER TRUSTS FOR CHILDREN In this chapter you will learn about trusts for children after 22 March 2006 including: The definition of trusts for bereaved minors and Age 18-to-25 trusts; The inheritance
More information(i) Additional funds required for the 20-month period from 1 August 2017 to 31 March 2019 Strategy A Strategy B
Answers Professional Level Options Module, Paper P6 (UK) Advanced Taxation (United Kingdom) March/June 2017 Sample Answers 1 Pippin Memorandum Client Pippin Subject Pinova business Prepared by Tax senior
More informationThesis Asset Management IHT and Tax Wrappers
For professional advisers only Thesis Asset Management IHT and Tax Wrappers Andy Zanelli FPFS, ACMI, Chartered Financial Planner Senior Technical Consultant This presentation is directed at Professional
More informationCapital Taxes Update and Planning Martyn Ingles FCA CTA
Capital Taxes Update and Planning 2017 Martyn Ingles FCA CTA CGT Update - Agenda PPR refresher Relief for gifts business assets and using trusts Goodwill on incorporation worth doing again? Transfer of
More informationAdvanced Taxation. Advanced Taxation. Specimen Exam applicable from June Strategic Professional Options
Strategic Professional Options Advanced Taxation Specimen Exam applicable from June 2018 Time allowed: 3 hours 15 minutes This question paper is divided into two sections: Section A BOTH questions are
More information