Francis Fitzpatrick 11 New Square discusses non-domiciliaries shield companies and the pre-owned assets rules
The pre-owned assets rules came into effect on 6 April 2005. The precise manner in which the rules will apply is causing confusion and concern. This article addresses one particular area: non-domiciliaries residing in the UK in a property owned by a non-resident company which in turn is owned by a non-resident trust. It has been assumed that the rules were not meant to apply to this situation but this article argues the rules on their plain meaning appear to catch it. Unfortunately the much anticipated guidance from the Revenue has done little to clarify the position.
Hypothetical Facts
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Francis Fitzpatrick 11 New Square discusses non-domiciliaries shield companies and the pre-owned assets rules
The pre-owned assets rules came into effect on 6 April 2005. The precise manner in which the rules will apply is causing confusion and concern. This article addresses one particular area: non-domiciliaries residing in the UK in a property owned by a non-resident company which in turn is owned by a non-resident trust. It has been assumed that the rules were not meant to apply to this situation but this article argues the rules on their plain meaning appear to catch it. Unfortunately the much anticipated guidance from the Revenue has done little to clarify the position.
Hypothetical Facts
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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