Buying UK property via an offshore company has traditionally been attractive for a number of reasons. These include:
A CGT exemption on disposal
An Inheritance Tax exemption for non UK domiciliaries
To preserve privacy
To avoid the need for UK probate
SDLT savings on the onward disposal There are however a number of changes to the tax treatment of offshore companies owning UK residential property from April 2013 where the property value exceeds £2 Million. These rules are being extended to properties valued above £500,000. These changes apply from 2015 and 2016. In addition there is likely to be a general CGT charge for non-residents selling UK residential property from April 2015. In this book we look in detail at precisely how offshore companies owning UK property are taxed both before and after April 2013 as well as the 2015 and 2016 changes. We look at all of the UK tax planning implications of using offshore companies for holding UK property and assess to what extent this is still a worthwhile tax planning strategy. Topics covered include:
Why purchase UK property via an offshore company
How to avoid UK corporation tax
How rental income is taxed in the offshore company and how to reduce UK tax to a minimum
How to maximise tax relief for interest
Inheritance tax treatment of the offshore company
Danger issues with UK "Shadow Directors"
How the ATED rules apply from 2012
Changes to the ATED rules in the 2014 Budget
The proposed new CGT charge on non-residents
What should companies within the ATED do now?
How should you purchase UK property going forward?
