Deemed domicile - legislation put on hold

Deemed domicile - legislation put on hold

Didn't find your answer?

In anticipation of the Deemed Domiciled rules as stipulated in the 2017 Finance Act, I formed a UK company and arrnaged for the director (my UK resident but non-domicile client) to transfer his overseas pure capital portfolio to his company at rebased values as at 6th April 2017. However, I now understand that he could be liable to CGT at 20% on the rebased enhancenment as those have now been remitted if the proposed legislation are not re-instated later on. What can be done ? Is it possible for him to purchase the shares in the portfolio back from his company and trigger the 30 days identification rules ? Most of the shares have gone up in value since 5th April 2017. This way one can generate capital losses to abrorb the capital gains on the transfer at rebased values. However we only 7 days to carry out these. Will connected party transfer rules interfere with the 30 days identification rules in this istance ? What do you think please ?  

Replies (1)

Please login or register to join the discussion.