Equiom seminar highlights new UK tax rules

Friday 16 February 2018

Guests and members of the business community gathered to hear presentations by tax experts from Equiom Solutions at a seminar held at the Old Government House Hotel, St Peter Port.

Speakers covered topics including tax planning for Channel Island residents, the proposed new rules regarding UK commercial and residential property and planning using ‘protected’ trusts.

The event was opened by Legal Director, Marcel Cariou and began with a presentation by Senior Tax Consultant Glenn Cassidy who addressed the topic of investing in UK property and the new tax rules which now apply to non-resident individuals, companies and trusts.

Mr Cassidy said: "From April 2017, shareholders of non-UK corporate entities holding UK residential property will be exposed to inheritance tax (IHT). Two consultation documents were also released by HMRC in 2017 concerning further amendments to the taxation of non-UK companies holding UK property. The first explores the proposed charge to UK Corporation Tax on non-UK resident companies holding UK property and is expected to come into effect from April 2020."

"The second concerns the charge to Capital Gains Tax (CGT) on gains realised by non-residents on disposals of UK commercial property including the proposed CGT charge on the disposal of indirect holdings of all UK property, effective from April 2019. Although these are only proposals and are out for consultation, it is likely that they will be enacted and as a result it is advisable to reassess how your UK property assets are structured ahead of April 2019."

Equiom Solutions Managing Director, Helen Woods then discussed UK tax planning for Channel Islands residents. Ms Woods highlighted an issue around those individuals with a UK domicile of origin who were born in the UK and have acquired a domicile of choice in the Channel Islands. She explained that if these individuals become UK resident at a later date, even for a comparatively short period of time, this will have adverse tax consequences.

Ms Woods went on to outline some planning opportunities, and explained the new deemed domicile rules, effective 5 April 2017 that impose non-UK domiciled individuals who are resident in the UK for more than 15 years deemed domicile status for all UK taxes. 

The seminars concluded with a Q&A session and closing remarks from Richard Tribe and Marcel Cariou.

Pictured: Left to right; Marcel Cariou, Helen Woods and Glenn Cassidy.