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ARTICLE · 11 NOVEMBER 2019

2017 UK Inheritance Tax Changes: Not All Is Lost!

Withers LLP
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The tax rules for UK residential properties have substantially changed over the last 6 years, reducing the appetite for investment in UK real estate by foreigners.

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The tax rules for UK residential properties have substantially changed over the last 6 years, reducing the appetite for investment in UK real estate by foreigners. One of the major changes, introduced in April 2017, dealt with the extension of the UK inheritance tax ('IHT') charges for foreign entities holding UK residential properties. Before, it was possible for foreign investors to escape IHT charges altogether by purchasing UK residential property through a non-UK holding vehicle (most frequently a foreign company) as, under the traditional IHT situs rules, such investors would be treated as owning non UK assets (i.e. the shares in the foreign companies). This meant that the shares in the companies could be gifted or transferred on death with no IHT implications.

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