Finance Bill 2019 has introduced further changes for non-residents in relation to capital gains so that from 6 April 2019 the following changes to the taxation of non-resident individuals will come into force:
Non-residents will be subject to tax on any direct disposals of UK land;
Non-residents will also be subject to tax on disposals where there is a substantial indirect interest in UK land.
Broadly the new rules will catch disposals of shares where the individual holds, or has held in the past two years, a 25% interest in a company which derives 75% of its assets’ gross value from UK real estate, subject to an exception where the company’s assets are used for qualifying trades. The definition must be checked very carefully if it is to be relied upon.
Disposals will need to be reported to HMRC within 30 days of the disposal so it is important that you talk to your usual contact about this as soon as possible if it is relevant to you.
