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HMRC's consultation describes the government’s proposals for the intended scope of new rules to charge non-residents to tax on gains realised from disposal of interests in UK property.

The proposed changes could inadvertently result in tax exempt investors such as Pension Schemes becoming effective UK taxpayers in relation to capital gains; investors who would otherwise be tax exempt on gains on direct investments could be disadvantaged by investing via (for example) non-UK fund vehicles.

Download the PwC response to the consultation here.