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Background

In the 2017 Autumn Budget, the government announced that from April 2019 UK tax will be charged on capital gains made by non-residents on direct and certain indirect disposals of all types of UK immovable property, extending existing rules that apply only to residential property.

Unlike most other major jurisdictions, the UK has not to date exercised its full taxing rights under relevant double tax treaties where non-residents dispose of non-residential UK immovable property.

The proposals therefore represent a significant change to the rules for taxing capital gains on immovable property (e.g. property held as an investment) by non-residents.

Proposals in more detail