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UK Property – still the real deal?

Despite post Brexit fears, real estate property investment continues although there seems to be a consensus that prime parts of London have slowed down.

Further tax complexity for real estate purchases has not cooled down and, from 6 April 2017, all UK residential property is in the scope of UK inheritance tax, regardless of the vehicle it is held in.  The rules apply even if the ultimate beneficial owner is or has even never been resident or domiciled in the UK.

Identifying who is caught and the extent of the exposure is critically important and therefore trustees and directors of non UK structures need to be aware of the new rules and the associated compliance requirements.

The prospect of further tax rules is not over. Consultation is underway as to whether non UK companies should be charged to UK corporation tax rather than income tax. Although this may appear to be just semantics, it would have wider ramifications not least with regard to the way interest on borrowings can be relieved but also the timing and delivery of tax returns.

We have vast experience in guiding our clients through the complexity to find the most appropriate solution for their circumstances and ensuring all reporting obligations are met.

There is plenty to think about, please contact me or your usual Mercer & Hole contact if there is anything you would like to discuss. 


As at 25 April it has been announced that the Non Dom changes and Inheritance Tax changes on residential property have been dropped pending the UK general election.

We are considering the impact of this delay and further advice will follow.

If you are affected please contact us urgently.




Date: 2nd May, 2017
Author: Liz Cuthbertson


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