Abstract This article deals with the cross-border tax issues resulting from (i) the purchase of real estate, (ii) the holding of this real estate and its renting out to lessees and (iii) a sale of the real estate at some point in time in the future, as well as (iv) gratuitous transfers through gifts or by way of death, and all of this under the tax law of the UK. The real estate may be purchased directly or indirectly through the acquisition of shares in a local company holding the real estate. The purchaser of the real estate may be a non-resident company or a non-resident individual. Introduction The four combinations mentioned in the abstract above may be depicted graphically as on page 40 of this issue of Trusts & Trustees, in the article ‘Cross-Border Planning For Real Estate: Austria’ by Niklas Schmidt. There has been a large amount of change since April 2012 effecting residential property, including: higher rates of stamp duty land tax (SDLT) (in particular for purchases of additional residential properties2 and for ‘enveloped’ properties3; the ‘annual tax on enveloped dwellings’ (ATED) and the related capital gains tax ‘CGT’ charge for residential properties held in companies (ATED-related CGT); non-resident capital gains tax (NRCGT); and a gradual restriction of rules allowing deduction of debt against UK property for inheritance tax (IHT) purposes. Together these changes mean that the UK tax treatment of the purchase, holding, and sale of residential property has altered significantly in recent years. In addition to the above, a raft of highly significant measures relating to the UK taxation of non-UK domiciled individuals and their offshore trust and company structures (with the potential, therefore, to impact upon transactions and structures involving UK residential property), have been incorporated into the most recent Finance Act – Finance (No. 2) Act 2017 – with effect from 6 April 2017 including, broadly, the following measures:4 to ensure that those non-UK domiciled individuals5 pay IHT on indirect holdings of UK residential properties held through offshore companies (including complex rules relating to related loans guarantees collateral, etc) so that in effect there is now transparency of ownership for IHT purposes for offshore companies, partnerships, or other ‘opaque vehicles’ of UK residential properties; to ensure that if they spend a significant time in the UK (broadly 15 out of the last 20 tax years for tax residents in the UK),6 that they become deemed domiciled in the UK for IHT, CGT, and income tax purposes—and so potentially find themselves subject to UK tax on their worldwide estate income and gains, whereas previously an individual who was domiciled outside the UK (as a matter of general law) was: (i) only subject to IHT on their UK-situated assets (unless, broadly, they had been UK tax resident for 17 out of the last 20 tax years); and (ii) only taxed with respect to their foreign income and gains if remitted to the UK (eg brought into or enjoyed in the UK)7; and to make significant changes to the treatment of non-UK resident trusts settled (directly or indirectly) by such individuals (subject to a form of protected status for some if they are not ‘tainted’ by additions of value to those trusts—very broadly defined including non-commercial loans—from 6 April 2017).8 Acquisition of real estate Direct acquisition9 SDLT10 Broadly, SDLT applies to the acquisition of leasehold and freehold property in England & Wales and Northern Ireland.11 It is paid by the purchaser on the acquisition price of the property, calculated by reference to a banded system of increasing rates for property exceeding GBP 125,000 in value, rising from 2 per cent at the lower end, up to 12 per cent for the excess over GBP 1,500,000.12 Also, since 1 April 2016, an extra 3 per cent ‘surcharge’ can apply to those rates if the property (or interest in the property) in question exceeds GBP 40,000 and it is an additional residential property (such as a second home or buy-to-let property).13 For the purposes of identifying what amounts to an additional property, foreign residential property owned by the purchaser is taken into account and the UK property as well. There are certain exceptions to the surcharge including, helpfully, where the property being bought is simply replacing the buyer’s main home. However, what constitutes an ‘additional property’ for the purposes of the surcharge is complex is not always intuitive (eg it can also include minor interests held by way of trust), and there are special rules with regard to joint purchasers and spouses. Other reliefs may be available if there is more than one property being bought, which is subject to the same transaction.14 There are separate ‘standard’ rates (and exemptions) for commercial and mixed-use properties. For commercial freehold property (such as offices, shops, agricultural land, etc), the highest rate is 5 per cent above GBP 250,000.15 Land registry fees16 HM Land Registry is responsible for keeping a register of registered land ownership in England & Wales and it charges a fee for its services including transfers of title to a new owner. The fee that they charge on a sale depends on the value of the property—currently ranging from GBP 20 (for property up to GBP 80,000) to GBP 455 (for property over GBP 1,000,000).17 Other fees/costs may also need to be taken into account.18 Indirect acquisition SDLT If a company19 acquires a UK residential property worth more than GBP 500,000, SDLT is payable at 15 per cent on the value of the property (even if the property is transferred without any payment being made), unless the property is let out to unconnected third parties or developed (ie in which case standard rates apply). If the property is already held by a non-UK company20 and the buyer purchases the shares of that company rather than the property direct, then no SDLT is payable. This approach necessitates appropriate due diligence on the relevant company (eg as to its liquidity, debts, etc.). In addition, it leaves open the possibility of other latent taxes, eg on gains (see below). For commercial property, standard rates apply. Land registry fees See as per direct acquisitions described above. Holding of real estate Direct holding Income tax This applies if the property is commercially let to an unconnected party. The maximum rate of income tax payable for the 2017/18 tax year in respect of the rental income would be 45 per cent, on income over GBP 150,000 and a UK tax return would be required. Tax can be deducted by an agent. If a loan/mortgage is used to buy the UK property, normally the interest on the loan may be deducted from the rental income when calculating the profit. However, from 6 April 2017, the level of the loan/mortgage interest deduction for individuals is gradually being restricted to a maximum of 20 per cent of the tax paid, ie it would not be deductible in full.21 IHT This applies to all UK-situated assets, wherever the owner is domiciled. The owner would potentially be liable to IHT at 40 per cent on death subject to a relatively small ‘nil rate band’ allowance (GBP 325,000 per person) plus if applicable, from 6 April 2017, a new ‘residence nil rate band’ (also known as the RNRB).22 However, there is an important exemption for gifts and inheritances between spouses of the same domicile.23 Loan financing, and (collateral for the loan), that is related in some way to the acquisition maintenance or enhancement of the property can create particular IHT issues discussed in more detail later in this article. Local authority taxes Council Tax is payable. The rate payable varies considerably based on the locality but in each case depends on the band that the particular property falls within—which is determined by the actual (or notional) value of the property as on 1 April 1991. However, the rates are comparatively modest (at least for high-net-worth individuals) so that, for example, even those in London falling within the highest band, Band H, (being valued at over GBP 320,000 on that date), typically pay well under GBP 3000 per annum in 2017/18, although rises for social care may be anticipated in the future. Indirect holding ATED ATED arrived as a new UK tax on 1 April 2013 and applies to ‘high-value’ residential properties held (wholly or partly) by ‘close’ UK or non-UK resident companies plus certain other entities,24 but not trusts. For the current period, 1 April 2017–30 March 2018, properties worth over GBP 500,000 fall into charge (the net having widened considerably since ATED first emerged when the property had to be valued at GBP 2,000,000 or more). The top rate now is GBP 220,350 per year on properties worth over GBP 20,000,000 and the bottom rate is GBP 3500 for properties over GBP 500,000. There are several banded rates in between.25 There are a number of exemptions and reliefs. The main one to note here is that there is no ATED charge if the property is rented out commercially to third parties. For most practical purposes this means: (i) leasing the property to someone wholly unconnected to the owner; and (ii) ensuring that it is not occupied (or made available for occupation) by the owner. Interestingly, there is no equivalent charge on direct trust ownership. Corporation tax If the property is let, rental income arising to the company is taxed at 19 per cent (much lower than if the property was directly held by an individual, typically at 45 per cent) and, under current rules, there is a possible opportunity to deduct the interest element of any loans/mortgages in full (in contrast, only partial tapered relief is possible for individual owners from 6 April 2017, as discussed above). Income tax/CGT Typically, trustees are liable to pay tax on rental income as per the above, generally at the highest rate on all income (45 per cent). Where there is ownership through a trust and there is income in the structure then there can be a charge by reference to the value of the benefit (eg rent-free occupation). Similarly, charges can arise by reference to trust gains in the context of such a free benefit. As a basic principle, income tax charges take priority over CGT (normally being at higher tax rates). There can be a risk of a ‘benefit in kind’ charge if the property is occupied by a director (or ‘deemed’ director of the company owner26) and he/she is permitted to occupy the property on non-commercial terms and is a UK tax resident. Here, the individual may be liable to income tax (at the maximum current rate of 45 per cent) in respect of the benefit provided by the company. IHT As noted above, a direct holding of UK residential property is subject to IHT in any event. However, unlike UK domiciled or deemed domiciled individuals who are subject to IHT on all their worldwide assets, certain UK residents or non-residents that were neither UK domiciled nor UK deemed domiciled27 could in the past avoid IHT on UK residential property by holding it indirectly via shares in a foreign holding company. However, with effect from 6 April 2017, the ability to use such a company as a ‘situs blocker’ has been removed, so that IHT will apply to an underlying residential property whether it is held in such a company or not—on the basis that the shares in the non-UK company are no longer treated as ‘excluded’ property for IHT purposes to the extent that their value derives (directly or indirectly) from UK residential property. As a result of the above, it may now be appropriate, in a small number of circumstances,28 to look at holding a UK residential property through a relevant property trust,29 with its own distinct IHT regime, so that rather than there being a 40 per cent IHT hit on death, as per the mainstream IHT regime, this particular trust regime imposes a 20 per cent charge when the property is added to the trust (plus up to a further 20 per cent if the donor dies within seven years); a 6 per cent IHT charge every 10 years during the life of the trust (a periodic charge); and a proportionate charge every time distributions are made from the trust between those 10-year anniversaries (an exit charge). It may be that some of those charges can be mitigated to some extent30 and if the running costs of the trust merit it, it may be easier to plan for these events rather than (otherwise) be taxed suddenly on an individual’s death at 40 per cent, at a date that cannot be predicted. IHT on property can also be paid over 10 years, albeit with the outstanding tax subject to interest. However, with trusts, one must be careful not to run into difficulties with gifts with reservation of benefits (GROBs). Broadly, the constituent parts of GROBs are made out when an asset (eg such as the property) is added to the trust (so that a gift is made) and the donee benefits or has the potential to benefit from the trust (so that a GROB in the property subject to the gift has been made). Unless that individual is irrevocably excluded from benefit (and does not in fact benefit on other than arm’s length terms—eg by occupying property in breach of trust), they are taxed on death at 40 per cent IHT as if they still owned the property in question, without the benefit of the spouse exemption. Worse still, the tax regime relating to relevant property trusts described above will also apply. Subsequently, excluding such a settlor from benefit is possible, but note that the GROB issue will not be removed for another seven years. For non-residential commercial property, there is still scope under current law for this to be held through an offshore close company and thereby made ‘excluded property’ that is not subject to IHT. A particular area of interest is that there are complex new rules, now with effect from 6 April 2017, that are designed to bring certain new loans into the scope of IHT that, broadly, are used to acquire, maintain, or enhance UK residential property (plus any related collateral such as rights of set-off/guarantees/security given over other assets in respect of such a loan). Although the IHT exposure on the collateral element should be capped to the value of the loan, in some circumstances, it nevertheless appears possible for the IHT exposure to exceed the value of the property, especially if the particular debt is not fully deductible as against the value of the residential property. Expert advice should be sought so that any financing is structured appropriately. Local authority taxes See as per direct holdings above. Sale of real estate31 Direct sale CGT The basic rate of CGT for individuals in respect of residential property gains is 18 per cent (which currently applies for taxable UK income and gains up to GBP 33,500 for 2017/18). The higher rate of CGT for individuals in respect of residential property gains is 28 per cent. Non-UK resident individuals are generally outside of the scope of UK CGT but following new legislation which has effect from 6 April 2015, non-UK residents are potentially subject to CGT on the post-6 April 2015 element of any gain realized on the disposal of UK residential property (by way of NRCGT) subject to the availability of any exemptions/reliefs.32 A modest Annual Exempt Amount is available to UK and non-UK residents in these circumstances of currently GBP 11,300.33 Main residence relief (sometimes called principal private residence relief)34 can be available to both UK and non-UK resident individuals on a disposal of only/main residence to exempt any gain arising if the individual (or their spouse) spends 90 nights at the property during each UK tax year and so long as it is their main worldwide residence. If the 90-night test is met for some tax years but not for other tax years, the availability of the relief is reduced proportionately. IHT Sale proceeds of the property are, once removed from the UK, outside the IHT net if the individual is neither UK domiciled nor UK deemed domiciled for IHT purposes.35 Indirect sale ATED/Corporation tax Where ATED is payable (normally the case unless the property is below the GBP 500,000 threshold or let on commercial terms to an unconnected third party), then ATED-related CGT is payable on a sale at a rate of 28 per cent on the post April 2013 part of the gain attributable to the period of time the property has been subject to ATED.36 Otherwise, CGT or NRCGT may be payable as per the above or Corporation Tax at 19 per cent.37 In relation to trust structures, watch the ‘matching’ of gains to previous periods of rent-free occupation, with no ability to pay away gains post 5 April 2017. IHT Sale proceeds of a close company (held by an individual who is neither UK domiciled nor UK deemed domiciled) holding UK residential property (or property directly/indirectly representing the same) resulting from a sale will not be regarded as ‘excluded property’ and so will continue to be liable to IHT for up to two years post sale even where removed from the UK.38 IHT is not normally an issue if the property itself is sold rather than the close company itself (subject to any other potential tax downsides eg if NRCGT is relevant, as described above). Gratuitous transfer of real estate Direct transfer CGT A lifetime gift is a disposal for CGT purposes, so the same rules apply as above on a sale. On death the value is rebased for CGT purposes, and there is no CGT charge.39 IHT Outright gifts of the property to another individual during the owner’s lifetime are potentially subject to 40 per cent IHT on the donor’s death within seven years of the gift (albeit that rate reduces if they die within three to seven years of the gift), and may also trigger CGT (see above). The IHT position is different if the donor retained some interest in the property given away, for example, by continuing to enjoy a benefit from it (typically by using the property themselves or receiving the rent from the property in the event it is let out), then there will be a GROB as explained above. Specific advice must be taken before making any gift as there may be other tax implications to consider, particularly if there is any outstanding borrowing secured on the property being gifted. Gifts into most trusts40 now normally trigger an automatic IHT entry charge at 20 per cent plus up to a further 20 per cent if the donor dies within seven years.41 IHT may also be payable up to 6 per cent of the fund value at each tenth anniversary of the trust (under the period charge)42 and on the value of any distribution from the trust to a beneficiary (under the exit charge).43 On death, the property will be subject to IHT at 40 per cent, although there is typically the small ‘NiI Rate Band’ (see above). Indirect transfer CGT A lifetime gift of the property to a company will be a disposal for CGT purposes, subject to any available reliefs, that may at least defer the CGT44 (eg in some circumstances gains realized on a gift into trust can be ‘held over’, ie passed to trustees).45 IHT A lifetime gift into trust will normally be immediately chargeable to IHT at 20 per cent with a further charge at 20 per cent on death within seven years with the potential for periodic and exit charges for the life of the trust, as previously described, at up to 6 per cent. A lifetime gift to a wholly owned company will not be subject to IHT. A lifetime gift to a company owned in whole or part by others may, depending on how the company is owned, trigger an immediately chargeable lifetime transfer at 20 per cent with a further charge at 20 per cent on death within seven years (subject to any reliefs). Watch also for GROB. Bart Peerless is a Partner at Charles Russell Speechlys in London. Bart advises individuals, trustees, and beneficiaries, based in both the UK and abroad, in relation to succession and estate planning (including tax and on the use of trusts and other asset holding vehicles). His clients include some of the world’s wealthiest families; in particular, he advises many UK and international business people and substantial landowners and frequently has to deal with cross-border tax and succession issues in the course of this work. Footnotes 1. This article is based on a paper that was presented in May 2017 and has been updated to the date of submission, 1 December 2017. This article represents general guidance only and does not constitute advice on any specific matter. It is recommended that you seek professional advice before taking any action. The author, Charles Russell Speechlys LLP and its employees and officers accept no liability for any action taken or not taken as a result of this article. 2. Such as second homes and buy-to-let properties—that since 1 April 2016 can be hit by a 3% surcharge above standard rates. See Finance Act 2016, s 128. 3. Broadly, residential property held by a closely held company. 4. Other measures include an opportunity for certain individuals affected by the changes to ‘rebase’ assets (ie eliminate latent gains); and, if relevant, to ‘cleanse’ certain foreign bank accounts where they contain a mixture of capital, gains and/or income (eg for easier extraction of clean capital that may be capable of tax-free remittance to the UK. It is important to note that certain non-UK domiciled individuals who were born in the UK with a UK domicile of origin, but who gain a domicile of choice in another jurisdiction (so called formerly domiciled residents’) will, under the expected measures, be deemed to be domiciled in the UK and pay tax on their world-wide income and gains on an arising basis in any year they are UK tax resident (without the benefit of the remittance basis) and they will also be potentially subject to IHT on their world-wide estate for tax years when they are UK tax resident (for at least one of the last two years immediately before that year). The trust protections and the ability to rebase assets or segregate funds etc. afforded to other non-UK domiciled individuals that does not apply to formerly domiciled residents. 5. Unless otherwise indicated, references in this article to ‘domicile’ means domicile at general law as determined by complex common law principles based upon long-standing case law in England & Wales (note that the concept of domicile is also different in Scotland). 6. UK tax residence is now determined by a statutory residence test. It takes a number of factors into account, not just the number of days spent in the UK, it is a complex area and the results are not necessarily intuitive. Consider Finance Act 2013, ss 218, 219 and schs 45 and 46 for further details (again see earlier IAETL paper by Bart Peerless). 7. Broadly, this measure seeks to ensure that such individuals lose the benefit of the remittance basis of taxation so that not only UK source, but also foreign source income and gains, are potentially taxed as they arise. 8. For further thoughts on this development, see Charles Russell Speechly’s recent briefing written by Dominic Lawrance in this link <https://www.charlesrussellspeechlys.com/globalassets/pdfs/tainted-love.pdf> accessed 5 January 2018. 9. For the purpose of this article, it is assumed, unless otherwise stated, that the real estate being acquired is not (or is not to be) directly or indirectly acquired or held subject to any loan debt or collateral; that it is residential property; and that where it is let out it is by way of a standard commercial lease that does not qualify as a ‘furnished holiday let’ for the purposes of the Income Tax (Trading and Other Income) Act 2005, ch 8, pt 3 (ie that it is not simply property rented out as holiday accommodation which has its own rules and reliefs). 10. See Finance Act 2003, pt 4. 11. Since 1 April 2015, Scotland replaced SDLT with its own Land and Buildings Transaction Tax that is similar to SDLT but with different rates. Similarly, it is anticipated that Wales will also adopt their own Welsh Land Transaction Tax from 1 April 2018. 12. An additional 1% may be payable for certain leasehold purchases if the net present value of the rent is more than GBP 125,000. Consider Finance Act 2003, sch 5. 13. Ostensibly, this measure was intended to correct imbalances in what was then an overheating UK residential property market. 14. It may be appropriate in some circumstances to claim Multiple Dwellings Relief (consider Finance Act 2003, s 58D and sch 6B) that can mean the applicable SDLT rate is calculated by reference to the average purchase price rather than the aggregate purchase price of the properties or, in the alternative, there is a separate relief for purchases of six or more properties in a single transaction (albeit in that scenario such properties will normally be subject to lower non-residential commercial rates ie currently a maximum of 5%). 15. An additional 2% may be payable for certain leasehold purchases if the net present value of the rent is more than GBP 5 million. Consider Finance Act 2003, sch 5. 16. HM Land Registry offers a fees calculator via this link http://landregistry.data.gov.uk/fees-calculator.html. 17. The fees are currently doubled if the application is not made electronically. 18. Such as for conducting local authority searches, (eg to identify if there are any planning permission issues or local road building projects, etc) index map searches or searches of the charges register, plus any legal conveyancing mortgage lender or survey fees, or consent fees (eg if the property is leasehold) etc. 19. For the purposes of this article, it is assumed that the property holding company in question is a closely owned and controlled company but not a mere nominee unless otherwise stated. 20. Perhaps a lot less common from 6 April 2017 assuming a significant number of such individuals may have already ‘de-enveloped’ their UK residential property by taking out of the ownership of an offshore company into personal ownership, in anticipation of the IHT changes outlined elsewhere in this article. 21. Consider Finance Act (No 2) 2015, s 24. 22. Consider Inheritance Tax Act 1984, ss 8D to 8M. Broadly, this measure increases the usual nil rate band to GBP 425,000 from 6 April 2017, rising to GBP 500,000 from 6 April 2020 if the residential property (that has to have been occupied by the deceased at some time during his ownership) is left to direct descendants. If the deceased dies owning more than one residential property, an election can be made as to which property the RNRB will attach. However, the RNRB is subject to a taper in respect of estates worth over GBP 2 million (whereby it is reduced by GBP 1 for every GBP 2 by which an estate exceeds the threshold), and for practical purposes it ceases to be relevant for estates worth in excess of GBP 2.35 million (or combined estates of GBP 2.7 million in the case of spouses). For UK residents who are not domiciled or deemed domiciled in the UK, the threshold only applies to assets in their estates which are within the scope of UK IHT (ie UK situated assets). 23. This would also be the case if a non-UK domiciled spouse made a gift/bequest to a UK spouse, but not vice versa. If, for example, a UK domiciled individual made a gift/bequest to a non-UK domiciled spouse, the value of the spouse exemption is capped to the value of the nil rate band, currently GBP 325,000, under Inheritance Tax Act 1984, s 18(2), albeit subject to a mechanism for the donee to elect, if appropriate, deemed UK domiciled status for IHT purposes to qualify for the full spouse exemption. Consider Inheritance Tax Act 1984, s 267ZA. 24. Such as an open-ended investment vehicles, unit trusts or partnerships with a corporate partner. 25. The value of the property for the purposes of the bands currently relates to the value as on 1 April 2017. 26. In short, if the company owner/shareholder is not formally appointed as a director of the company, but the directors of the company are accustomed to act in accordance with his/her directions, that individual would be considered a ‘shadow director’ of the company. 27. Both at common law and under the deeming provisions based on the ‘15 out of 20’ tax year residence rule referred to previously. 28. Notably, for older clients where a potentially significant 40% charge on death cannot be mitigated by other means (such as by way of life assurance). 29. Consider Inheritance Tax Act 1984, ch III, pt III. For certain older (pre-20 March 2006) life interest trusts the individual with the life interest is broadly treated as if they owned the assets in their own right with 40% IHT if their interest in possession ends on their death. Other rates/rules apply if the interest in possession ends during the life tenant’s lifetime. 30. For example, with respect to the proportionate and exit charges, by property sales before the ten-year anniversary (although the timing of sales needs to be considered carefully, especially when shares are in a holding company are to be sold). 31. Assuming an arm’s length sale to an unconnected party (ie with no element of bounty/gift). 32. NRCGT was introduced by Finance Act 2015, s 37 and sch 7. 33. However, certain non-UK domiciled individuals who claim the remittance basis of taxation do not qualify. Consider Income Tax Act 2007, s 809G. 34. Consider Taxation of Chargeable Gains Act 1992, ss 222–226B. 35. Per the new ‘15 out of 20’ tax year residence rule as on 6 April 2017. 36. See Taxation of Chargeable Gains Act 1992, s 1(2A). ATED-related gains are subject to CGT rather than Corporation Tax. 37. Companies do not benefit from the Annual Exempt Amount, referred to above, but trustees can enjoy half the rate available to individuals. 38. Per a two-year IHT ‘tail’ that applies from 6 April 2017. 39. Taxation of Chargeable Gains Act 1992, s 62(1)(a)(b). That is, the personal representatives of the deceased are deemed to acquire the property at its market value at the date of death which becomes the base cost for any subsequent disposal. 40. Assuming here that they are ‘relevant property trusts‘for the purposes of Inheritance Tax Act 1984, pt III (and not another form of trust such as a Qualifying Interest in Possession Trust). 41. Inheritance Tax Act 1984, ss 2(1) and 7. 42. ibid, ss 64, 66, 67. 43. ibid, ss 65, 68, 69. 44. Consider Taxation of Chargeable Gains Act 1992, s 162. 45. ibid, ss 165 and 260. © The Author(s) (2018). Published by Oxford University Press. All rights reserved.
Trusts & Trustees – Oxford University Press
Published: Feb 1, 2018
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