The announcement by the Chancellor of the Exchequer in his Autumn Statement on 3 December 2014 of radical changes to the stamp duty land tax (SDLT) regime, coupled with forthcoming extension of capital gains tax (CGT) to disposals of residential property owned by non-residents, and an increase in the rates of the annual tax on enveloped dwellings (ATED), mean that those owning and thinking of purchasing UK residential property need to consider more carefully than ever the appropriate ownership structure from a UK tax perspective. 

The extension of the CGT regime to non-UK residents, and the increase in ATED rates, builds on legislation which has been introduced over the last three years, the object of which has been to discourage the ownership of UK residential property intended for owner occupation through offshore structures.

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