The Government will shortly be introducing changes to the rules
on Inheritance Tax on any UK residential property held by those
domiciled outside the UK (commonly referred to as
"non-doms"), where such assets are held through a non-UK
company.
The current situation is that property owned by way of non-UK
company is excluded from liability for Inheritance Tax; however,
from the 6 April 2017, property will no longer be
'excluded' from this liability. This development means that
Inheritance Tax will now be charged on the value of a UK
residential property which is owned in an offshore corporate
structure upon the death of an individual shareholder.
Likewise, the new rules will apply where an offshore company is
wholly owned by an offshore trust. The result being that trustees
will have to pay Inheritance Tax on the value of the property at
ten year anniversaries and quite possibly, will have to pay an
Inheritance Tax exit charge if the property is removed from
