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Taxing gains made by non-residents on UK immovable property


CGT consultation
Untitled copy

Consultation response


The draft legislation for the Capital Gains Tax changes, along with a response to the consultation was published on 6th July 2018. You can find the draft legislation here. The proposed treatment of offshore funds is set out in annexe A of the summary of responses to the consultation which can be found here. Annexe A can be found on page 33.


Overall, we believe that the proposals for offshore real estate funds are positive. Considerable work needs to be done on the detail, but HMT and HMRC have clearly been listening to the concerns of the industry and plan to continue listening.


The proposed changes are now subject to another consultation. This further consultation will close on Friday 31 August 2018. Real estate industry trade organisations will continue to work with HMT and HMRC. We will feed in our comments via the Association of Real Estate Funds (AREF).


John spoke on a conference call for the Real Estate Investor Forum regarding the CGT changes for non-residents. The speakers were:


Melville Rodrigues, Charles Russell Speechlys (chair)

Tim Jones, PwC.

John Forbes


You can hear the recording and download Tim Jones slides here.


John was also quoted in an article in IPE Real Assets. You can read it here.


John spoke on a panel at a PwC seminar on this subject on 26th July.

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