Carter Lemon Camerons LLP was among the first organisations, on Budget Day itself, to share the worrying news from the 2014 Budget that foreign investment in UK residential property was to suffer two major hits in the form of a 15% SDLT charge for corporate entities buying such property from a £500,000 base (down from the £2m figure pre-budget) and application of ATED (the Annual Tax on Enveloped Dwellings) at that same £500k threshold too.
What emerges from the detail (as opposed to just the headlines/sound bites) is very interesting. Investment, in its purest sense, is to be exempted from both of these horrors but only if the corporate investor is incredibly careful.
Done properly and carefully both the punitive SDLT rate can be avoided and also a zero tax ATED return can be justified but the dwelling in both cases must be rented out (or available to be so) and never occupied by anyone remotely associated to the owner (no director no shareholder no relative of either etc).
As I say, the Angel is in the Detail!
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