In the 2017 Autumn Budget, the government announced its intention to extend CGT to non-residents in UK real estate, bringing to an end an advantage enjoyed by overseas investors. The UK has been almost unique among jurisdictions in the developed world for not applying tax to non-residents on gains made on their UK real estate assets.

A major concern for exempt entities investing via real estate funds and JV vehicles will be that they do not suffer tax leakage as a result of the changes that they would not have suffered if they held assets directly.

As a priority, we will be responding to the consultation in relation to some technical points which we believe need clarifying and which we would be happy to discuss with you.