In the 2012 UK budget the government announced proposed changes
to the taxation of UK residential property held by offshore
entities. The changes, other than stamp duty, if adopted are to
take effect from 1 April 2013.
The proposed new regime is intended to discourage ownership
through an offshore vehicle and imposes additional taxes on
property owned in this manner.
STAMP DUTY
Already in place, for new acquisitions of property bought by a
company with a value of £2 million or more is the rise in
stamp duty to 15%. This applies to both non-UK companies and those
incorporated or resident in the UK for tax purposes. The purpose of
the legislation is to counter the avoidance of subsequent property
stamp duty taxes by arranging for the sale of the property by share
transfer rather than re-registration of the actual property to a
new owner.
