Tax impact of returning corporate structures to the UK

KEY POINTS

• An offshore company holds UK property but is affected by proposed new inheritance tax rules.
• Corporate structures may remain relevant for long-term investment growth.
• The benefits of a share-for-share exchange and a UK holding company.
• Advance clearance from HMRC is recommended.
• Will non-UK resident companies holding UK property be brought within the corporation tax charge?

Recent years have seen a raft of changes to the taxation of residential property and more changes were expected from 6 April 2017. Before the anticipated rule changes property that was not ‘UK property’ and which was held by non-UK domiciled individuals was referred to as ‘excluded property’ and was not subject to UK inheritance tax. Offshore company shares were classed as ‘excluded property’ even though the underlying assets were UK...