S198 election on overseas property?
I am aware that a property investor investing in overseas commercial property can claim capital allowances on the same basis that they can on UK property. Likewise if there is a surplus of allowances, these can (currently) be offset (without a cap) against general income – S121 ITA 2007.
OK so far so good.
My question is that on a future sale what happens? Do the allowances reverse or can the taxpayer make use of S198 CAA 2001 provisions to sell the asset for an agreed tax WDV / £1 even though the purchaser could very well be a non-UK taxpayer. Is there anything to stop a 198 election from being effective? I know there is a requirement under S201(3)(f) CAA2001 to have tax district and ref numbers for the persons making the election but there is actually no stipulation this has to be UK references??!
Any help would be much appreciated.
- Cloud accounting package 107 1
- Incorporation after the start of trading 986 39
- Do I walk away from these accounts? 775 14
- Setting up offshore to avoid paying VAT 481 15
- Legal structure of a group of friends producing a free newspaper 243 6
- Offshore company (Guernsey / Isle of Man) 144 3
- PAYE – Directors NI 225 6
- Next Move 314 12
- Ltd Co and 'grant' income 391 7
- when to file SA return if closed SA in the middle of the year 171 4
- S445 tax V's new dividend tax 219 3
- Large PAYE tax refund to Employee 333 3
- Personal Tax Accounts. Are we all doomed. 698 10
- Accounts treatment of assets at cessation date 268 10
- Seeking advice: Vehicle usage 155 3
- Accountant won't release working papers 2,224 34
- Casual Driver 244 4
- Self Assessment Software 631 20
- Furnished Lettings - expenses normally bourne by tenant 343 7
- How does HMRC give tax relief to Muslims for borrowing costs? 1,259 10
- Self employed and HMRC Worldwide Subsistence Rates 630
- VAT on Export Outside EU and Conditional Sale 394
- Acrobat Checkbox Help for New 64-8 394
- Property letting & CAs 376
- 2015 tax year end 371
- Interest paid - do new rules affect Tax Credits? 369
- FCA regulated company in a small group 335
- What's happened to Smith's Taxation 230
- MLR and benefitting from the disclosure 223
- Market Invoice (P2P invoice discounting) tax treatment 217