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Tax-efficient transfer of properties from an offshore company to a UK one.
My client is Spanish but he is moving to the UK in mid-May to take up full-time employment here. For UK residence status purposes it seems that he will have a split year for 2017-18 with the UK part starting when he arrives. Subject to the outcome of the Brexit negotiations he is likely to live in the UK indefinitely.
The client owns a number of UK residential properties through a company registered in the British Virgin Islands (BVI) and these are managed and controlled by professional directors there. This structure was established for inheritance tax purposes but this plan has been defeated by recent changes to the excluded property rules. The properties are let to unconnected third parties and therefore the annual tax on enveloped dwellings is not in point.
Once the client assumes UK residence he will be directly taxable here on...
