Francis Clark - Property Sector Annual Update

Francis Clark
Property Sector
Annual Update
06 October 2015

www.francisclark.co.uk
Chairman’s Introduction
John Endacott
Head of Tax
Francis Clark LLP

Housekeeping

Programme
• Budget and property tax update
Heather Britton, Tax Director
• Succession planning ideas for property
businesses
John Endacott, Head of Tax
• Grants and funding update
David Armstrong, Corporate Finance Director
Coffee break

Programme
• VAT – Top 7 queries relating to property
Julie Towers, VAT Partner
• Energy and sustainability
Andrew Killick, Corporate Finance Partner
Damian Lannon, Tax Partner
• Dwellings and residential property – Panel
discussion
Chaired by John Endacott
Lunch

Budget and Property
Tax Update
Heather Britton
Tax Director

What we will consider
• Restriction of tax relief for ‘buy to let’ landlords
• Tax relief for capital expenditure
• Outlook for furnished holiday lets
• Profit extraction from property companies

Restriction of
higher rate relief
for buy-to-let
landlords

• Finance costs are a tax deductible expense until April 2017
• Gradually introducing “tax reducer” at 20% of finance costs
Introduction – residential property
finance costs
Year Finance costs
claimed as
deductible
expense
Finance cost
claimed as “tax
reducer” at 20%
2017/18 75% 25%
2018/19 50% 50%
2019/20 25% 75%
2020/21 onwards 0% 100%
• Headline impact = only basic rate tax relief achieved

Who is affected?
• Higher & additional rate taxpayers
• Trusts
Unaffected:
• Furnished Holiday Lets
• Let commercial property
• Basic rate taxpayers
• Corporates
Question: who should own residential property?

How the tax reducer is calculated
• Income tax deduction = 20% x lower of:
• Finance costs not allowed as deductible expense
• Rental profits for the tax year
• Finance costs – includes interest & arrangement fees

Example
Take a highly geared landlord with
• Gross rents of £100,000
• Expenses other than interest £30,000
• Interest expense £50,000
• Other income of £11,000

Position 2016/17
Rent 100,000
Expenses (80,000)
Rental profit 20,000
Other income 11,000
Total income 31,000
Less personal allowance (11,000)
Taxable income 20,000
Tax at 20% 4,000

Tax during transition – “highlights”
Tax year Interest expense
allowed
Tax reducer Tax to pay
2016/17 50,000 - 4,000
2017/18 37,500 2,500 4,100
2018/19 25,000 5,000 6,600
2019/20 12,500 7,500 9,100
2020/21 - 10,000 11,600

Possible effects
In this example:
• Landlord has become a higher rate taxpayer
• A high income child benefit charge may be due

High income child benefit charge
• If the landlord has 2 children and a student loan
• “Commercial” profit each tax year = £31,000
Tax year Total tax Effective tax
rate
Tax rate on
property
income
2016/17 5,230 16.9% 26.2%
2017/18 6,455 20.8% 32.3%
2018/19 11,153 36.0% 55.8%
2019/20 15,493 50.0% 77.5%
2020/21 19,118 61.7% 95.6%

Additionally…
• Taxpayers being pushed above £100,000 = personal allowance
withdrawn
• He/she becomes an additional rate taxpayer
• Consider impact on pension contributions
• From April 2016 reduced annual allowance
• £40,000 tapered down to £10,000 (watch income > £110,000)
• Where tax reducer can’t be used fully – carry forward unused
interest
• Major headlines not hit papers yet!

Tax relief for
capital
expenditure

Wear & Tear allowance
Current rule:
• 10% of “relevant rental amount” can be deducted from profits
• Only available on fully furnished lettings
New proposed rules from April 2016:
• Wear & tear 10% allowance abolished
• No relief on initial capital outlay
• Relief on actual costs of replacements
• Claim on furniture/furnishings, appliances, kitchenware

Who is affected?
• Residential properties
• Unfurnished, part furnished, and furnished properties
• Not applicable to:
• Furnished Holiday Lets (FHLs)
• Commercial properties
• Capital Allowances still available for these properties

Furnishings include
• movable furniture or furnishings, such as beds or suites
• televisions
• fridges and freezers
• carpets and floor-coverings
• curtains
• linen
• crockery or cutlery

Not included ….
• baths
• washbasins
• toilets
• boilers
• fitted kitchen units
Why? Because replacement would be treated as a repair

Annual Investment Allowance
- commercial property & FHLs
• 100% deduction for capital expenditure
• April 2014 – December 2015 £500,000
• January 2016 onwards £200,000
• Watch year ends straddling this date
• March 2016 year end – only £50,000 spend qualifies in final 3 months
• January 2016 level better than £25,000 default
• Capital allowances in FHL/commercial property
• Importance on acquisition/disposal
• Properties already held – consider opportunities

Outlook for
Furnished
Holiday Lets

Furnished Holiday Lets (FHLs)
• Strict letting conditions must be met
• Claim all finance costs as a deductible expense
• HMRC may challenge non-commercial FHLs
• Claim capital allowances (including annual investment allowance)
• Inheritance Tax relief – most will not qualify

Profit extraction
from property
companies

Dividend taxation changes
When?
• 6 April 2016
Main changes?
• Abolition of dividend tax credit (10%)
• Introduction of new £5,000 “dividend allowance”
• Change in rates at which dividends taxed

Dividend rates
Currently From April 2016 Increase
Basic rate 0% 7.5% + 7.5%
Higher rate 25% 32.5% + 7.5%
Additional
rate/trusts
30.6% 38.1% + 7.5%

How does the dividend allowance work?
• First £5,000 of dividend taxed at 0%
• The dividend allowance does not reduce the amount of income
subject to tax
• Dividends use up basic & higher rate bands
• No draft legislation published, so detail unclear
• HMRC published factsheet giving brief overview

Basic rate taxpayer
Tom has dividend income of £4,500 each year
What is the impact?
Basic rate taxpayer Higher rate taxpayer
2015/16 Nil (as in basic rate) £4,500 x 25% = £1,125
2016/17 Nil (as < £5,000) Nil (as < £5,000)

Additional rate taxpayer
Will owns shares in a profitable property development company
He extracts £500,000 in dividends per annum
Rate of dividend tax Tax payable
2015/16 30.6% £153,000
2016/17 38.1% £188,595
Extra tax £35,595

Winners & losers!
Winners
• Higher rate taxpayers with
dividends < £5,000
• Higher rate taxpayers with
dividend income < £21,667
• Additional rate taxpayers with
dividend income < £25,400
Losers
• Basic rate taxpayers with
dividends greater than £5,000
• Will pay tax in 2016/17
• Previously no tax!
• Low salary and high dividend
strategy

Comments – extraction rates
• New dividend rules have eroded tax benefits of incorporation
• Dividends still more tax efficient than salary
• Salary/bonus – wholly & exclusively test if trading
Dividend Salary
Basic rate 26% 40%
Higher rate 46% 49%
Additional rate 50% 53%

Planning points
Consider dividend pre-April 2016
• Loan back to company
• Charge interest on loan
• first £1,000/£500 tax-free from April 2016
• savings rate £5,000 at 0% from April 2015
Who owns the shares?
• Spousal transfers
• Gifts

Entrepreneurs’
Relief and Joint
Ventures

Entrepreneurs’ Relief – joint ventures
• Entrepreneurs’ Relief reduces Capital Gains Tax rate to 10%
• Trading includes property development but excludes property
rental
• Changes introduced in March 2015:
• Exclude activities carried out by joint venture companies
• Joint venture – parties with < 50% interest in a company
• Impact = only companies with significant trade of their own qualify for
Entrepreneurs’ Relief
• Proposed changes have attracted criticism and alternatives are
being considered

Budget and
Property Tax
Update

Succession planning
ideas for property
businesses
John Endacott
Head of Tax

Issues
• The family
 need to satisfy different family groups
 business acumen and risk issues
 distribution of the estate (will issues)
• Inheritance tax on death?
• Potential loss of income if business passed on
• Capital gains tax on lifetime gifts
• Between a rock and a hard place?

Property businesses
• Property development/dealing
• Property rental
 Residential
 Commercial
 Holiday lettings
 Caravans & park homes
• Mixture of activities
• Is it a business for tax purposes?
• Ownership structure – personal/company/trust

Property tax status for companies
Property Rental Property
Development
Property Dealing
General tax status INVESTMENT TRADING TRADING
Company
Accounting
treatment
Fixed asset Trading stock Trading stock
Realisations Capital gain
(Indexation)
Trading profit Trading profit
Shareholders
CGT:
Entrepreneurs’ relief
Hold-over relief
X
(unless
holiday lets)
 
IHT:
Business Property relief
X  X

Assessing qualification for tax reliefs
• 50%+ for business property relief
• 80%+ for capital gains tax reliefs
• Farmer/Balfour tests
 turnover
 profit
 capital employed
 time spent
 overall impression
• Group aspects

Impact of inheritance tax
Value of company, say £10m
Half share (discounted), say £3m
Inheritance Tax at 40% £1.2m
Extracted as dividend (38.1%) £1.94m
Effective tax rate 65%

Tax planning strategies
• Achieving business property relief qualification
 non-statutory clearance procedure
• Gift of existing value (but capital gains tax)
• Pass on future growth
 using a trust
 re-structuring shares
 new property business
• Pension planning (outside fund)
• Mixture of the above

Family planning
• Who’s involved in the business?
• Can a development business be continued?
 risk profile implications
 invest into a property portfolio for maintainable dividends
 consider trust ownership
• Shareholder arrangements
 preference shares for wider family
 shareholders’ agreement & tie into wills
 family constitution approach
• Split up the group?

Personal property portfolios
• Transfer into trust (but lifetime inheritance tax - 20%)
• Inheritance tax planning easier in a corporate structure
• Consider incorporation
 impact of interest tax relief restriction
 SDLT issues
 capital gains tax relief may be available
 joint ownership or property business?
 is there a partnership?
 partial trust ownership possibility
• Borrowing costs and loan complications

Succession
planning ideas
for property
businesses

Grants and Funding
Update
David Armstrong
Corporate Finance Director

Contents
• Developers
• Owner / occupiers
• House builders
• State of the funding market
• What makes a good funding application

Developers – what is the current situation?
• GAP funding – what has happened?
• European Programme 2014 – 2020
• Access very limited:
- Workspace Development Grant
- Watch this space – ‘Project Bank’

Developers - what is the current situation?
• UK Government Funding
• Growth Deal - c£200m for projects in line with the
HotSW LEP Strategic Economic Plan
• Mixture of infrastructure, transport, housing, IT
schemes
• BUT, includes an Unlocking Growth Fund to invest in
key employment sites – await further details
• Mixed messages – make use of the ‘Project Bank
concept’

Owner / Occupier
North Devon + South West Growth
Fund
Area HotSW LEP Wider South West – as
far as Wiltshire and
Dorset
Applicants All companies – but some priority sectors
Level of grant £25K to £499K £15k to £1m
Timetable Open for business Open for business
• More positive re grants
• Capital expenditure Job creation

Owner / occupiers
• Eligible sectors:
• Advanced engineering, marine, creative, and
environmental technologies
• Manufacturing, food processing, electronics and
pharmaceuticals
• Ineligible sectors:
• Retail, warehousing, tourism, PROPERTY
DEVELOPMENT, and others
• Local market
• Tenants? – commercial point
• More positive – grants available

Housing developments
• Housing crisis – National Housing Federation - ‘supply
is some 50% of demand’
• Plethora of Government Activity:
• Housing Growth Partnership - £100m equity type fund
• Builders Finance Fund - £525m loan type fund
• £26m Fund towards brownfield development for first time
buyers – August 2015
• LEPs’ Growth Deals
• Further detail on Homes & Community Agency website
• Lots of activity – are these schemes delivering?

State of the funding market - banks
• Selective appetite
• Increasing flexibility in face of competitive market
• Pricing still falling?
• Greater focus on debt servicing not just security value
• Interest rates speculation – 2% by 2019
• Cautious optimism??

Challenger banks
• Vince Cable
• More and more entering market
• Virgin, Paragon, Aldermore, Metro, Williams & Glyn
• ‘We have advanced over £1bn to small trading businesses
and professional property investors since coming to market
in 2011.’ Shawbrook
• Will they challenge the high street? Time will tell

Peer to peer lending
• Increasing popularity
• 2011 - £90m, 2014 - £1.2bn, …. 2020 - £12.3bn!
• Higher interest rates but quick decisions
Assetz Capital – ‘Shovel ready housing schemes’
Folk 2 Folk – ‘kick starting multi- million pound
commercial property developments’

What makes a good funding application
• Match what you are doing with the most appropriate
source of funding
• Investment ready
• Business plan
• Financial history
• Financial projections

Summary
• Developers - mixed messages, watch this space
• Owner / occupiers – more visibility re grants; be careful
of the preferences
• House builders – plethora of Government initiatives
• State of the funding market – changing on a daily
basis; greater variety; increasing competitiveness
• Investment ready – be prepared and self-challenge!

Keeping up to date
• Our role is to keep abreast of what is happening
• http://www.francisclark.co.uk/services
Dave Armstrong
David.Armstrong@francisclark.co.uk
07810 056164
Paul Crocker
Paul.Crocker@francisclark.co.uk
07780 331841
Andy Killick
Andrew.Killick@francisclark.co.uk
07771 945513
• Or your usual Francis Clark contact

Top 7 VAT queries
relating to property
Julie Towers
VAT Partner

1. Are there any special rules for new
commercial buildings?
• What buildings are affected?
• New buildings or partly completed buildings excluding dwellings, relevant
residential buildings and relevant charitable buildings
• Includes buildings with occupancy restriction i.e. holiday accommodation
• New or partly completed civil engineering works e.g. roads, bridges, car
parks and golf courses
• Building is new when it less than 3 years old from the date of
completion
• Completion is the earlier of: issued date of certificate of practical
completion or date first fully occupied

1. Are there any special rules for new
commercial buildings?
• Why does it matter?
• Sale of freehold interest in a new building is taxable
• Sale of freehold interest in ‘old’ building is exempt (unless Option to Tax
has been made)
• Rules apply however many times the asset is sold before it is 3
years old
• Rules do not apply to anything less than the freehold interest

2. I am selling commercial property, do I
need to charge VAT?
Property is not being sold as part of a business
• Standard rated if
• Selling freehold interest and less than 3 years old
• Any interest in the land and an Option to Tax has been made
• Exempt if
• Selling any interest and more than 3 years old and no Option to Tax
• Less than freehold interest, less than 3 years old and no Option to Tax

need to charge VAT?
Property is being sold as part of a business
• Outside the scope if the property is being sold as part of a Transfer
of a Going Concern (TOGC) for VAT purposes and criteria met
• Examples
• Sale of a property rental business e.g. industrial estate with tenanted
properties
• Sale of a trading business e.g. sale of a manufacturing business including
the factory

need to charge VAT?
Property is being sold as part of a business
• If the sale of the property would otherwise be taxable additional
criteria
• Buyer must make an option to tax
• Anti-avoidance legislation must be considered
• Complicated case law on this subject

3. Can I get rid of an Option to Tax?
Owner/landlord
• After 20 years using form VAT
1614J
• 6 month cool off period using form
VAT 1614C. Only applies if no
supplies made
• Automatic revocation 6 years
since held a relevant interest
Buyer/tenant
Buyer/tenant can disapply the
vendor’s/landlord’s option to tax in
certain situations
• Building to be used or converted for use
as dwelling or for relevant residential
purpose
• Use for a relevant charitable purpose by a
charity
• Land sold to a housing association which
will construct dwellings on the land
• Land sold to an individual to construct a
dwelling for non-business purposes

3. Can I get rid of an Option to Tax?
Option to Tax Unit – 50 working day delay

4. What is a dwelling for VAT purposes?
• It depends!
• Criteria as defined in the VAT Act 1994
• Self-contained
• No internal access to another dwelling
• No restriction on separate use or disposal
• In accordance with planning

4. What is a dwelling for VAT purposes?
• Increasing number of Tribunal cases over the last 3 years
• Issues
• Retention of façade/parts of former buildings
• Annexes
• Can a dwelling comprise more than one building?
• Permitted development rights

5. When is the reduced rate of 5%
available for construction services?
• Conversions that involve a change in the number of single
household dwellings in a building. Includes
• Conversion from commercial use to dwelling e.g. barn conversion
• Conversion of house to flats
• Conversion of building to multiple occupancy (bedsits)
• Conversion of building to relevant residential use e.g. student
accommodation
• Renovation of residential building that has been empty for more
than 2 years

5. When is the reduced rate of 5%
available for construction services?
• 4 June 2015 CJEU ruled that the UK application of the reduced
rate of VAT for energy saving materials is contrary to EU law
• Currently the reduced rate applies to the installation of energy
saving materials, and the goods themselves when provided with
qualifying services
• The reduced rate will continue in the short term.
• Government is ‘considering the implications of the decision’
• HMRC has announced that no change will be implemented until
Finance Act 2016

6. What are the VAT implications of a
change of intention?
• Initial recovery of VAT should be based on the intended use of the
expenditure at the time it is incurred
• If before the original intention is fulfilled the intended use changes,
the original recovery of VAT should be re-visited. The rules apply
broadly where the change of intention is within 6 years.
• The rules could result in either a payment of VAT due to HMRC or
a repayment of VAT due to the taxpayer

6. What are the VAT implications of a
change of intention?
Example
• Arthur bought a piece of land in 2012 for £500k plus VAT (£100k).
He intended to build and sell new dwellings on the land
• As the sale of new dwellings is taxable at the zero-rate, Arthur
recovered the VAT of £100k in 2012
• In 2015 Arthur decided to rent the new dwellings on ASTs. The
income from the short lets is exempt for VAT purposes
• Arthur should repay the £100k VAT to HMRC in the VAT period in
2015 in which he changes his intention

7. Should an overseas supplier be charging
UK VAT?
• 2014 First Tier Tax Tribunal case of Muster Inns
• Facts
• Muster Inns based in the UK and VAT registered
• Non-established supplier from Guernsey provided building services
• Overseas supplier was registered for VAT in the UK and charged VAT at
the standard rate
• Muster Inns recovered the VAT, recovery challenged by HMRC on the
basis that the overseas supplier should not have charged VAT and Muster
Inns should have accounted for VAT using the reverse charge procedure

7. Should an overseas supplier be
charging UK VAT?
• First Tier Tax Tribunal agreed with HMRC and held that the non-
established overseas supplier should not have charged UK VAT
and that Muster Inns should have accounted for the VAT on its
VAT returns using the reverse charge procedure.
• VAT reclaimed by Muster Inns was disallowed by HMRC
• This could apply to you if
• You are VAT registered in the UK
• An overseas supplier has a UK VAT registration but no establishment in the
UK

Top 7 VAT
queries relating
to property

Energy &
Sustainability
Andrew Killick
Corporate Finance Partner
&
Damian Lannon
Corporate Tax Partner

The Learning Clinic
Energy &
Sustainability
• Where are we since the budget ?
• Should you still invest in
renewables ?
• Investment tax reliefs

What is the future of electricity generation?
Centralised Decentralised
• Less vulnerable to
failure of a single
power station
• Less electricity losses
in transmission
• Self-sufficiency for
towns / local areas
• CEO National Grid “The idea of large power stations for
baseload is outdated”
• Smart Meters to be installed by 2020

Where are we since the budget ?
• The landscape has changed significantly since election
• Government appears to be favouring expensive energy
• Reduction in subsidies
• Devolve planning decision making powers to local
authorities
= Inconsistency in Government aims V actions
“Greenest Government ever” is becoming distant memory
(eg shifted Vehicle Excise Duty (VED) so a Porsche pays as much as a Prius – a decision the AA
said would lead to drivers using more polluting cars!).

• Wave of policy announcements to reduce / remove support
• Justifications based on affordability (which is under review)
• Lack of clarity may undermine investment in sector
• Developer and investor uncertainty
• Sparked number of legal cases and petitioning
• Expectation more shale and nuclear………
Is Government policy misguided short termism or just lacking
any direction ?
What has been done ?

Tax benefits withdrawn
The good old days
FiTs + generous tax relief
Now
EIS Subsidised generation of electricity =
qualifying activity
Subsidised generation of electricity = non-
qualifying unless through a community
project
Annual Investment
allowance
100% tax deduction up to £500k From 1 Jan 2016, 100% tax deduction up
to £200k
Capital allowances Claimed at 20%/18% Only eligible at special rate 8%

Investor tax reliefs
2015/16
EIS VCT SEIS SITR*
*EU state aid pending
Maximum
investment –
individual
£1m £200k £100k £1m
Maximum fund
raise – company
£5m p.a. £5m p.a. £150k in 3 yrs £5m p.a.
Income tax relief 30% 30% 50% 30%
Minimum holding
period
3 years 5 years 3 years 3 years
One year
carry-back
Yes No Yes Yes
Dividends Taxable Exempt Taxable Taxable
Capital gains Exempt after 3
years
Exempt
Exempt after 3
years
Exempt after 3
years
Capital gains
deferral
Yes No No Yes
Capital gains tax
holiday
No No Yes No

Further restrictions - EIS
• State aid restrictions
• Purchase of trade and assets
• Existing shareholdings’ requirement
• Permitted maximum age requirement

Social Investment Tax Relief
• An alternative to EIS?
• Community projects
• Equity and debt
• Index-linked returns
• Current limitations and state aid approval

0
5
10
15
20
25
30
35
40
01 January
2010
01 January
2011
01 January
2012
01 January
2013
01 January
2014
01 January
2015
01 January
2016
(p/kWh)
FiT's - Significant Reduction Since 2010
Wind Turbine (500kW)
Solar PV (10-50kW)
Stand-alone PV
Export Tariff
Should you still invest in renewables ?
2010 2011 2012 2013 2014 2015 2016
Technology FiT Reduction on 2010 Levels
Wind (500kW) 51%
Rooftop Solar (10-50kW) 70%
Stand-alone PV 88%
2015/2016 values

Report commissioned by REA : http://www.r-e-a.net/upload/uk-solar-beyond-subsidy-the-transition.pdf
Domestic PV LCOE vs. retail electricity tariff
Grid parity for domestic PV with residential electricity prices
expected in the next 1-2 years. Cost reductions of 70% in
last 5 years and projected
35% over next 5

Report commissioned by REA : http://www.r-e-a.net/upload/uk-solar-beyond-subsidy-the-transition.pdf
Non-domestic PV LCOE vs. retain electricity tariff for industry and services
Grid parity for non-domestic PV with industrial electricity
prices expected within the next 5 years.

Is investing in renewables worthwhile ?
• Project costs falling
• Solar and onshore wind could be subsidy free in 2-3 year time
• Energy costs (gas and electric) expected to rise
• Tax benefits may still be available
• Post subsidy EIS availability – look at overall investor returns available
without subsidy
• Capital allowances and Annual Investment Allowance still available
• So……. Yes:
• Small scale – direct into properties (site specific issues to overcome)
• Community schemes – benefit from EIS and FIT – short term window
• Larger scale with no FIT, but possibly EIS

Panel session -
some recent tax
changes to
residential property

UK residential property/dwellings
Recent tax changes – increasing impact for South West properties
Date ATED/SDLT Event
21 March 2012 SDLT
SDLT
7% rate introduced for residential property
over £2m
15% special rate introduced for companies
acquiring residential property over £2m for
non-qualifying purpose
1 April 2013
5 April 2013
ATED
ATED-related CGT
Introduced for properties over £2m used
for non-qualifying purpose
20 March 2014 SDLT
15% special rate threshold reduced to
£500,000
4 December 2014 SDLT New bands and rates introduced
1 April 2015 ATED Starting threshold reduced to £1m
1 April 2016 ATED Starting threshold reduced to £500,000

Annual tax on enveloped dwellings (ATED)
Initially introduced to counter perceived SDLT abuse.
Annual charge from 1 April 2013 for UK dwellings/residential property:
• owned by companies, corporate partners and collective investment
schemes,
• worth over £2m on 1 April 2012 or date of acquisition if later.
• used for a non-qualifying purpose.
ATED-related capital gains tax from 6 April 2013 for disposal of “ATED”
properties:
• loss of indexation relief
• 28% capital gains tax rate on “ATED-related” gain
• restriction of losses against other company gains

Annual tax on enveloped dwellings (ATED)
• £65m was expected to be collected in ATED – HMRC actually
collected:
• £100m 2013/14
• £116m 2014/15
• 89% of receipts in respect of London properties
• 52% of receipts from houses in London borough of Westminster
Relatively small impact on South West due to £2m starting threshold.

Changes introduced for the “foreign” owner
• Non- residents previously not liable to UK capital gains tax
• From 6 April 2015 liable to UK capital gains tax on UK residential
property/dwellings
• Rebasing of property value at 5 April 2015
• Tight reporting deadlines:
• return must be submitted to HMRC within 30 days of completion,
• capital gains tax liability may be payable within 30 days of completion
(with exceptions)
• From April 2017 proposed changes for non-doms:
• Foreign wrappers holding UK residential property looked through for
inheritance tax purposes
• Excluded property trusts affected
• HMRC consultation document and draft legislation yet to be published

Panel Session
John Endacott, Julie Towers,
Heather Britton and Karen Bowen

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Francis Clark - Property Sector Annual Update

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Francis Clark - Property Sector Annual Update

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