The law affecting the taxation of non-UK domiciliaries continues to change rapidly. This short online update package, written by subject-matter expert, Jenny Wilson-Smith, examines the changes that have taken place since April 2018 and those proposed for 2019.
Topics covered include:
Changes to the taxation of offshore trusts, which took effect from April 2018. In particular:
- the CGT treatment of capital payments received by non-resident beneficiaries
- the CGT treatment of certain payments to close family members of the settlor
- the introduction of new onward gifts rules for both income tax and CGT purposes
An overview of proposed changes contained in Finance Bill 2019 to the taxation of capital gains of non-UK residents disposing of UK land including:
- extension of gains charge to commercial property and widely held companies
- introduction of tax on gains on disposals of interests in property rich companies
- taxation of gains of non-resident companies disposing of UK land to corporation tax
- abolition of ATED-related CGT.
This update will be of interest to all UK-based lawyers, accountants, tax advisors and financial planners dealing with non-UK domiciled clients, as well as their non-UK based counterparts looking for a more detailed understanding of the UK tax position for their international clients.