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ARTICLE · 15 DECEMBER 2014

Changes To Offshore Loans For UK Property

Wedlake Bell LLP
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Back in 2008 the Finance Act introduced sweeping changes to the way non-UK domiciled individuals resident in the UK were to be taxed.

United KingdomTax
Camilla Wallace
Camilla Wallace
Kate Davies
Kate Davies

Background

Back in 2008 the Finance Act introduced sweeping changes to the way non-UK domiciled individuals resident in the UK were to be taxed. The Government's principal objective was to extend the definition of "remittance" so that it would be easier for overseas income and gains to be taxed in the UK when they (or assets representing the same) were brought, enjoyed or used in the UK. Having said that, the legislation was far from clear cut and as a result HMRC published detailed guidance on how it would treat certain arrangements in light of the new legislation. Some of that guidance was on "relevant debts" – i.e. where an overseas loan is brought to the UK (e.g. to purchase a UK property) and the security for the loan comprises untaxed foreign income and gains.

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