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Taxing gains made by non-residents on UK immovable property


CGT consultation
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Major proposed changes to the taxation of non-resident investors in immoveable property were announced on Budget Day 2017.


You can read our initial comments regarding the Budget in our newsletters here and here.


The Association of Real Estate Funds (AREF) held seminars to discuss the proposed changes on 16th and 22nd January 2018. You can read an event summary here.


PwC held a seminar on the proposed changes on 16th January 2018, attended by senior representatives from HMRC and HM Treasury. John presented at the seminar and you can download his slides here.


The panel discussion with the representatives of HM Revenue & Customs and HM Treasury at the PwC seminar included several slightly alarming moments that suggest that the complexities of applying the proposed rules to collective investment schemes had not been understood. It was also concerning that they appeared to be unaware of the FCA consultation on open-ended funds, the delayed outcome of which is still awaited. The positive news was that there is clearly a willingness to work with the industry to try to resolve some of the problems that the rules would create. Less positive was the caveat that this would only be if this could be achieved without major changes to the proposals or any delay to the proposed timetable.


You can find our response to the consultation here.


HMRC and HMT published draft legislation and a repsonse to the consulation on 6th July 2018. You can find more details and our comments here.


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