Philip Hendy recently wrote in the Jersey Funds Association’s (JFA) blog.
In this blog Philip discusses the changes which will take place on 6 April 2019 when non-resident capital gains tax will be payable on both commercial and residential property disposals, whether direct or indirect.
“There is a rebasing to market value or historic cost if this provides a better outcome which given current valuations may be the case.
These changes will affect all offshore entities that derive at least 75% of their gross asset value from UK land. Rules will be introduced to avoid inter-company artificial boosting of non-land assets. For investors with less than 25% ownership disposing of their interest in the property holding entity for two years preceding the sale there is no tax consequence.
Jersey collective investment entities have key decisions on two elections that need to be fully considered. These options stem from a period of positive consultation between the UK authorities and a range of industry stakeholders, including the JFA, and are designed to prevent the potential for multiple layers of tax in structures.”
Read the full blog here.