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Legal Updates

Developments in law or practice in our jurisdictions

New inheritance tax rules to impact non-domiciles holding UK property through offshore companies and trusts

Publication Date:
9 December 2016

On Monday, 5 December, the Government announced the results of the consultation on the proposed reforms to the taxation of non-domiciles. As we have previously advised the new legislation will have practical implications for those who purchase, hold or sell UK residential property through offshore structures. 

If you are a foreign domicile who owns or has an interest in residential property in the United Kingdom – whether or not it is occupied by you, your family, or paying tenants – the changes to the UK's inheritance tax regime may mean that it is time to urgently review your current arrangements with respect to that property – especially if it is held through an offshore company or trust before the changes come into effect on 5 April 2017.

If you are advised to de-envelope your property as part of a solvent liquidation of the property holding company, you may wish to consult a new FAQ guide prepared by Harneys which details the steps involved. For more information on how the above may apply to your situation please contact us.

Click here for the Solvency liquidations FAQ guide.

Related articles:
Update: ATED and IHT – Is it time to push the envelope (or unwind the trust)?
Is it time to push the envelope (or unwind the trust)?