The UK Government has issued a consultation paper on the tax treatment of gains accruing on disposals of non-residential real estate in the UK by non-UK residents, significantly increasing the tax exposure of non-UK owners of UK non-residential real estate in the UK and updating the taxation of UK residential real estate.
The proposals will form the basis of legislation which will take effect from April 2019.
Historically, non-UK residents were not liable to capital gains tax on disposals of UK real estate. This first changed in 2013 for corporate owners of personal use residential real estate (ATED related CGT) and was widened in 2015 to include all direct owners of residential real estate, be they individuals or corporates (non-resident CGT), other than funds or other widely held companies.
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