Taxation of individuals investing in the UK Anne Healy-McAdam Tax Director

Agenda Non domiciled individuals Business Investment Relief Tax on Property Non residents Annual Tax Enveloped Dwellings Non Resident Capital Gains Tax Privacy

Non domiciled individuals Remittance basis – income and gains arising in or remitted to the UK Remittance basis charge arises after 7 years and increases after 12 years Longer term residents -15 out of 20 years; deemed domiciled World-wide income and gains Rebasing at 5 April 2017 Cleansing Bank accounts pre April 2019

Business Investment Relief Available for foreign income or gains remitted to the UK used to make ‘qualifying investment’ Strict deadline Money must be invested within 45 days Otherwise taxable Claim Qualifying Investments Direct investment into a company/hybrid or stakeholder company (not to 3rd party) Ord Shares/preferences Loan (drawdown treated as new loans)

BIR- Disposal A Chargeable event can arise: Company loses its status Full or partial disposal Benefit received 2 or 5 years elapsed no trade commenced Effect: Reinvestment within 45 days; or repatriated offshore To avoid being treated as a remittance Although part of funds can be retained for CTD to meet CGT on a disposal

Taxation of Property A person is taxable on profits from property business if land situated in the UK Non residents Landlords scheme By application Must comply with tax obligations Gross rents From April 2020 will move to CT rules

Property issues ATED is flat annual charge based on value of the property ATED – ‘non natural person’ high value residential property now property over £500K Complete ATED return by 30 April, Relief available on commercial lettings Non Resident CGT Rate 28% NRCGT Return SDLT higher rates

Privacy Issues Register of Overseas Entities Current and new owners Compliance Criminal offence, penalties Crown Dependencies and Overseas Territories Exchange information on company beneficial ownership Law enforcement UK to impose requirement in UK Sanctions AML Bill ( Not Jersey, Guernsey or IOM)