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The increasing costs of de-enveloping residential property

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The extension of UK tax to gains realised by non-resident persons on the disposal of shares in property rich companies means that a non-resident wishing to ‘de-envelope’ residential property by liquidating the property holding company may now be subject to a double charge to tax on the increase in the value of the property (from 2015) and the increase in value of the shares (from 2019). It may therefore be best to act sooner rather than later in extracting property from these structures in order to mitigate the increasing double tax costs.
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