Finance bill 2018/19: Good news for overseas investors in UK REAL ESTATE…
It has been clear for some time that, from April 2019, non-UK residents would become subject to UK tax on gains when disposing of investments in UK commercial property or substantial interests in UK “property rich” vehicles. Whilst draft legislation has been produced and consulted on, a missing piece of the jigsaw has, until now, been details of how non-residents who invest through “collective investment vehicles” such as offshore property units trusts and other collective investment schemes (CIVs) would be taxed.
CIVs are attractive as they can usually be structured to allow pooled investment in UK real estate in a stamp duty land tax efficient way, but without the CIV itself adding an additional layer of direct tax (compared to direct investments into property), and without prejudicing any tax exemptions of the investors.
Source read full article: https://www.lexology.com/library/detail.aspx?g=cdd8ed21-4c36-4bec-8af5-10e1d43d51c0