Client Alerts

Gains on UK Real Estate held by Non-Residents

With effect from 6 April 2019, the UK’s capital gains tax (CGT) regime for non-residents was extended to include UK commercial property as well as indirect disposals of UK real estate (whether residential or commercial).For disposals made on or after 6 April 2019, non-resident individuals, trustees and partnerships are chargeable to UK capital gains tax and non-resident companies are subject to corporation tax.

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UK real estate investments – non-resident companies must register with HMRC for Corporation Tax under new regime applying from April 2019

From 6 April 2019, capital gains made by non-resident companies from disposals of all UK real estate (both residential and non-residential) are within the charge to UK Corporation Tax (“CT”). From 6 April 2020, all income (e.g. rents) of non-resident companies from UK real estate investments will also be within the charge to CT.

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Ireland – Central Register of Beneficial Ownership of Companies

The European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) Regulations 2019 (S.I. No. 110 of 2019) (the “Regulations”) were issued by the Irish Finance Minister on 22 March 2019.

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Publications

UK Resident Non-Doms: UK Tax Relief When Working Overseas

UK resident employees are generally taxable in the UK on worldwide employment income.  However, non-domiciled employees may be eligible for UK tax relief in respect of income attributable to duties performed outside the UK, under the ‘Overseas Workday Relief’ (OWR) provisions. To benefit from OWR, the individual must be a remittance basis user for the tax year in question, the earnings must be paid into a non-UK account and must not be remitted to the UK.

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Gains on UK Real Estate held by Non-Residents

With effect from 6 April 2019, the UK’s capital gains tax (CGT) regime for non-residents was extended to include UK commercial property as well as indirect disposals of UK real estate (whether residential or commercial).For disposals made on or after 6 April 2019, non-resident individuals, trustees and partnerships are chargeable to UK capital gains tax and non-resident companies are subject to corporation tax.

Read more
UK real estate investments – non-resident companies must register with HMRC for Corporation Tax under new regime applying from April 2019

From 6 April 2019, capital gains made by non-resident companies from disposals of all UK real estate (both residential and non-residential) are within the charge to UK Corporation Tax (“CT”). From 6 April 2020, all income (e.g. rents) of non-resident companies from UK real estate investments will also be within the charge to CT.

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Tax at a glance

Hover over a pin to see that nation’s tax rates. Click for more detailed information.

map
      Corporation Tax-main rateCorporation Tax-reduced rateCapital Gains TaxVAT - main rateReal Estate TaxReal Estate Transfer TaxCapital/Stamp Duty on SharesWith-holding Taxes - Non Treaty - DividendsWith-holding Taxes - Non Treaty - InterestWith-holding Taxes - Non Treaty - RoyaltiesWith-holding Taxes - Non Treaty Various - Fees
UK19%-20%20%-0% - 15%0.5%-20%20%-
Ireland12.5%0%33%23%-1% - 2%1%20%20%20%-
Austria25%-25%20%0.2% - 1%3.5%-25%-20%20%
Belgium33.99%6.8% - 31.93%33.99%21%1.25% - 2.5%0% - 12.5%Max €80030%30%30%-
Brazil15%-15-22.5%17%-19%0.3% - 1%2% - 6%--15%15%-
Cyprus12.5%--19%-3% - 8%0.6%--5% - 10%-
France33.33%15%33.33%20%-5.09%3%30%-33.33%33.33%
Germany15.825%-15.825%19%1.5% - 2.3%3.5% - 6.5%-26.38%26.38%15.83%-
Hong Kong16.5%----0% - 15%0.2%--4.95%-
Italy27.9%-27.9%22%0.76%9% - 13%€200 fixed26%26%22.5%-
Luxembourg26.01%5.2% - 22.08%26.01%17%---15%---
Malta35%0% - 10%35%18%-8% - 10%2%----
Mexico30%-30%16%-2% - 4%-10%4.9% - 21%25% - 35%25%
Netherlands25%5% - 20%25%21%Variable6%-15%---
Portugal21%17%21%23%0.3% - 0.8%5% - 10%Variable25%25%25%15% - 25%
Russia20%0 - 8.5%-7%3% - 16%Variable0.2%15%20%20%-
Singapore17%0% - 8.5%-7%3% - 16%1% - 3%0.20%-15%10%17%
Spain25%25%28%21%0% - 1.3%6% - 7%1%19%19%24%24%
Switzerland8.5%-8.5%7.7%-1% - 3%0% - 1%35%35%--

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