What’s happened?
The UK government’s long awaited final proposals for CGT on non-UK residents owning UK residential property have now been published (see Implementing a capital gains tax charge on non-residents: summary of responses (HM Treasury and HMRC).
The government believes that CGT should apply to disposals of UK residential property by residents and non-residents alike. The government states that it is ‘rectifying the unfairness in the system that currently allows non-residents to escape UK CGT on disposals of UK property that are or could be used as a dwelling house’.
The plans for the new CGT charge were first announced in the 2013 Autumn Statement and a consultation document followed in March 2014. Mishcon de Reya responded to the consultation document and took part in working groups with HM Treasury and HMRC...