UK residential property owned through certain non-UK structures and lenders providing debt finance will be subject to IHT.
Who should read this?
People holding or lenders financing UK residential property that is held through certain non-UK structures.
Summary of proposal
From 6 April 2017 UK residential property owned through certain non-UK structures will be brought within the charge to UK inheritance tax (IHT) regardless of the residence and domicile status of the ultimate owner. Any debt used to finance such property will itself be subject to IHT in the lender’s hands.
Key changes from the draft legislation
The draft legislation contains the following changes to previous versions:
6 April 2017
We understand and support the Government’s aim to ensure parity of all UK residential property owners in terms of their exposure to IHT. However, the rules are widely drawn, encompass what previously appeared to be accepted planning. It is a shame that the opportunity was not taken to help people simplify complex property ownership structures.
For further information see:
Mike Walker +44 (0)20 7311 8620
Rob Luty +44 (0)161 246 4608
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