Although yesterday's Autumn Statement did not include any further details about the proposed new tax charges on UK residential property worth more than £2 million, the UK Chancellor did confirm that the draft legislation will be published next Monday 11th December.
We are counting down the hours until then, eager to find out how 'non-natural' owners (or Zombies, as we have come to know them) of such high value residential properties will be affected.
The new Stamp Duty Land Tax (SDLT) thresholds of 7% for individuals and 15% for Zombies on residential property above £2 million were introduced with effect from April 2012 but the proposed introduction of an annual charge and the extension of capital gains tax on such properties were the subject of consultation and will not bite until April 2013.
Will the awaited draft legislation effectively slay all Zombies or only prevent new Zombies from being created?
We know that many of you have been reviewing your property portfolios in order to identify any residential property that might be worth over £2 million. You should also consider any properties that are just below this threshold (or potentially likely to exceed this threshold in the near future).
Collas Crill's checklist is a tool to help you assess structures in which the UK property is held in a company with an overlying trust.
There is one for Guernsey: CHECKLIST FOR TRUST AND CORPORATE SERVICE PROVIDERS: HIGH VALUE UK PROPERTY RESIDENTIAL STRUCTURES
Earlier this year we presented a seminar with UK experts Thomas Eggar addressing the UK Government's proposed new taxes on high value UK residential property. The event covered the nature of the tax changes, effects on client structures holding property through an offshore company and how those might be mitigated.
Look out for details of a follow up event in the new year, again in conjunction with Thomas Eggar, in both Guernsey and Jersey.
With our expertise in corporate, fiduciary and UK property law, Collas Crill are uniquely placed to assist you with property structuring - so please don't hesitate to contact us.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.