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Non-Domiciliaries and the Pre-Owned Assets Rules

 
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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