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Non-residents and UK real estate: the April 2019 changes

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The Finance Act 2019 has greatly extended the territorial limits of UK tax where capital gains are concerned. Non-resident persons are now taxable not only on UK residential property gains, but also on UK commercial property gains. However, the most radical aspect of the FA 2019 is the introduction of new rules allowing non-resident persons to be taxed on gains realised on the disposal of assets that are not themselves UK land, but derive some or all of their value from UK land. These new rules, generally known as the property-rich company rules, are the primary focus of this article.

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