The Government announced in its Budget on 21 March 2012 that high-value dwellings held within offshore structures will become subject to a more adverse UK tax regime:
- The new rules will apply from April 2013
- They will apply to dwellings valued at over £2 million
- Ownership by a company, unit trust or partnership with a corporate partner will be caught
- A high annual charge to tax will apply to these structures
- Sales will be brought within the scope of capital gains tax
- No changes are proposed to the inheritance tax benefits
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