1. Taxation of individuals investing in the UK
Anne Healy-McAdam
Tax Director

2. Agenda Non domiciled individuals Business Investment Relief
Tax on Property
Non residents
Annual Tax Enveloped Dwellings
Non Resident Capital Gains Tax
Privacy

3. Non domiciled individuals
Remittance basis – income and gains arising in or remitted to the UK
Remittance basis charge arises after 7 years and increases after 12 years
Longer term residents
-15 out of 20 years; deemed domiciled
World-wide income and gains
Rebasing at 5 April 2017
Cleansing Bank accounts pre April 2019

4. Business Investment Relief
Available for foreign income or gains remitted to the UK used to make ‘qualifying investment’
Strict deadline
Money must be invested within 45 days
Otherwise taxable
Claim
Qualifying Investments
Direct investment into a company/hybrid or stakeholder company (not to 3rd party)
Ord Shares/preferences
Loan (drawdown treated as new loans)

5. BIR- Disposal A Chargeable event can arise: Company loses its status
Full or partial disposal
Benefit received
2 or 5 years elapsed no trade commenced
Effect:
Reinvestment within 45 days; or repatriated offshore
To avoid being treated as a remittance
Although part of funds can be retained for CTD to meet CGT on a disposal

6. Taxation of Property
A person is taxable on profits from property business if land situated in the UK
Non residents Landlords scheme
By application
Must comply with tax obligations
Gross rents
From April 2020 will move to CT rules

7. Property issues
ATED is flat annual charge based on value of the property
ATED – ‘non natural person’
high value residential property now property over £500K
Complete ATED return by 30 April,
Relief available on commercial lettings
Non Resident CGT
Rate 28%
NRCGT Return
SDLT higher rates

8. Privacy Issues Register of Overseas Entities Current and new owners
Compliance
Criminal offence, penalties
Crown Dependencies and Overseas Territories
Exchange information on company beneficial ownership
Law enforcement
UK to impose requirement in UK Sanctions AML Bill
( Not Jersey, Guernsey or IOM)