ARTICLE
27 October 2016

United Kingdom Inheritance Tax Changes - To De-Envelope Or Not?

W
Walkers

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We are a leading international law and professional services firm providing legal, corporate and fiduciary services to global corporations, financial institutions, capital market participants and investment fund managers. With a global presence spanning the Americas, Europe, the Middle East and Asia, we advise on the laws of Bermuda, the British Virgin Islands, the Cayman Islands, Guernsey, Ireland and Jersey. With over sixty years of looking at the world through the same commercial lens as our clients means we deliver focused, clear, precise advice to get the deal done. Clients trust us to help them make good business decisions, create commercially sound products and strategies, resolve disputes and cement deals that are profitable. From offices across geographies, we deliver business-critical advice and service in the same time zones as our clients, covering asset management, investment funds, corporate, M&A, dispute resolution, finance, insurance, fintech, private capital and trusts, regulatory and more
The United Kingdom government has recently confirmed that non-domiciles who hold residential property via an offshore company will be subject to inheritance tax from 6 April 2017.
United Kingdom Tax
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  • within Accounting and Audit, Immigration and Insurance topic(s)
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Summary:

  • the United Kingdom ("UK") government has recently confirmed that non-domiciles who hold residential property via an offshore company will be subject to inheritance tax from 6 April 2017;
  • we understand that this is the latest in a raft of changes to the UK tax regime of non-domiciles designed to eradicate the previous advantages of owning UK residential property via offshore companies;
  • we are assisting clients 'de-envelope' their UK residential properties (i.e. transferring the property out of the offshore company's ownership) by way of voluntary liquidation in both the British Virgin Islands ("BVI") and the Cayman Islands; and
  • given the imminent date of implementation, and the lead time to complete such transactions, we are seeing an increase in the number of properties being de-enveloped by way of voluntary liquidation in both the BVI and the Cayman Islands.

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