Property funds held in offshore bonds by UK residents - final outcome

As previously communicated, HMRC legislation that came into force in April 2019 meant ‘UK property rich funds’ held in an offshore bond became subject to UK corporation tax on any gains on disposal.

The original legislation had consequences for UK residents with offshore bonds invested in ‘UK property rich funds’ as although the investor was UK resident, the offshore bond company was classed as the non-resident ‘beneficial owner’.

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