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Taxing non-residents on UK property gains: the rules for funds

Overview

There is much for funds to be positive about in the latest draft of the rules taxing non-residents on gains from UK land. In particular, the transparency and exemption elections are included in roughly the form expected, and HMRC has clearly listened carefully to concerns raised by the industry. However, there remain a number of challenges, not least navigating the long and complex legislation applying the new rules to funds and their investors.