An immediate rate of 15% Stamp Duty is now payable on new purchases of UK residential property by a "non natural person" (eg a Company) with a value in excess of £500,000.
In addition, two new tiers have been introduced for Annual Tax payable on certain UK real estate owned by a non natural person. Applicable residential properties with a value of between £1,000,000 and £2,000,000 will be subject to the Annual Tax with effect from 2015 and those with a value of between £500,000 and £1,000,000 will take effect from 1st April 2016.
Steve McCafferty, Director of IQE Real Estate said "the UK property market is a key asset class for international investors who continue to acquire high value properties through corporate vehicles and trusts. Whilst there has also been a consultation announced extending Capital Gains tax to non UK residents disposing of UK property, importantly, from an Isle of Man perspective, certain rental, development and commercial properties continue to remain outside of the target catchment, which is very positive for our international client base who remain active in these sectors".
A number of anti avoidance measures were also announced, some affecting Group corporate structures and as anticipated, the taxation of remote online gambling will change from 1st December 2014. Additionally, IQE will be closely monitoring a new consultation for Horserace Betting Levy, which may apply to our gaming clients.
Further information on these and other announcements will follow on release of the Finance Bill 2014, due shortly.
We have the expertise to assist with multi-jurisdictional fiduciary services for international structures
On a recent transaction we worked closely with IQE to set up and run a corporate structure to facilitate a new residential development in London. We found the IQE team responsive and proactive. It was clear that their property experience added value and understanding of the clients’ requirements on the project. Christine Jackson, Partner, Real Estate Group, Lawrence Graham LLP