In the 2017 Autumn Statement, Chancellor Philip Hammond announced that from April 2019 tax will be charged on gains made by non-residents on disposals of all types of UK immovable property, extending existing rules that apply only to residential property.  From 2019, gains on UK Property will be subject to either Capital Gains Tax or Corporate Income Tax, depending on how the property is held.  The proposed changes will likely have a dramatic impact on 'offshore' structures established to hold UK commercial property and facilitate investment from both domestic and foreign investors.

* 1. How concerned are you about these changes to taxing gains made by non-residents on UK immovable property?

* 2. The HMRC consultation period on these changes closes on Friday 16th February. Have you, or do you intend to, respond to this document?

* 3. Are you consulting with advisers on these changes?