Articles & Video
Complex offshore structures – traps and pitfalls: a practical guide
There has been a growing trend over recent years for the development of bespoke and complex holding structures to accommodate the needs and sensitivities of ultra-high net worth individuals. Often, the clients originate from civil law jurisdictions and as a consequence are unfamiliar with trusts and the fiduciary relationship created. There is (understandably) suspicion.
I can see clearly now…
In recent years, there has been a positive deluge of reporting initiatives affecting UK individuals, entities and structures with a UK connection. Some of these have come from the USA (so-called “FATCA”), some from the OECD (the Common Reporting Standard), others from the EU (as a result of the 4th Anti Money Laundering Directive) and others are simply ground-breaking initiatives by the UK government.
Developments in UK Real Estate Taxation in Recent Years
For decades, the UK has welcomed overseas investors with interests in residential and commercial properties with its benign tax regime. Admittedly there had been a few mildly irritating snags: an increasingly high stamp duty land tax (SDLT), unavoidable taxation of rental income, and inheritance tax issues. These may have been mitigated with the help of foreign property owning companies and various debt instruments, whose costs were dwarfed by the ensuing benefits.
Buy-To-Let Landlords: Yet Another Stealth Tax?
Over the last couple of weeks there has been much discussion over the possibility that Buy-To-Let landlords may find themselves subject to income tax at rates up to 45 per cent on any gain they make when disposing of a property, instead of capital gains tax at 18 per cent or 28 per cent. HMRC has provided reassurances but the legislation needs to be far clearer
Principal Private Residence Relief: Time to Rebuild?
Tax reliefs and their use continue to come under scrutiny, and Principal Private Residence (PPR) relief from capital gains tax is currently in the firing line. A recent National Audit Office (NAO) report highlighted “scope for wide-scale misuse” and called for more scrutiny, in respect of PPR in particular, due to the £18bn cost to the Exchequer each year. But what is PPR, has it gone wrong and, if so, how can we fix it?