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A case of congestion

08 December 2015 / Paul Belsman
Issue: 45230 / Categories: Comment & Analysis , Land & property

The changes to the regime relating to the annual tax on enveloped dwellings.


  • For disposals after 5 April 2015 non-residents are chargeable to capital gains tax on profits arising on the disposal of residential property.
  • There is a rebasing of values at 5 April 2015.
  • Returns are required to be filed by 30 days after disposal.
  • This supplements the annual tax on the enveloped dwellings regime.
  • Further inheritance tax reform for ownership by non-residents.


The term congestion is used rarely when describing taxation provisions but arguably it could be said to apply to the ownership of UK residential property by non-residents given the influx of new legislation over the past three years.

The policy objective that appeared in the 2012 budget proposals and which was followed swiftly by a consultative document was fundamentally directed “to...

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