An overseas client (non UK domicile and non UK tax resident) wishes to buy a house in London for £2.5m for investment purposes. His intention is to rent it for a year or so and if the value goes up, sell it.
Should he buy it under an off-shore company or under his own personal name ?
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offshore company...
If he purchases via an offshore company, he will need to be aware of the ATED rules including SDLT at 15% rather than 7% (from which he might get an exemption if he is letting it commercially).
http://www.hmrc.gov.uk/ated/basics.htm
He also needs to be aware of s13 TCGA92
http://www.hmrc.gov.uk/manuals/cgmanual/cg57200+.htm
and also, depending on how he funds the purchase, the transfer of assets abroad rules
http://www.hmrc.gov.uk/manuals/intmanual/intm600010.htm
Amongst other things....
He needs advice from a specialist in this area. It is complex.