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Property Tax Planning

Author: Andrew Crossman

ISBN: 9781526507358

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Publication Date: 2019

Publisher: Bloomsbury Professional

Law As Stated At: 31 January 2019

Property Tax Planning

Property Tax Planning

Previously updated by Philip Spencer at BDO LLP, Property Tax Planning, Sixteenth Edition had been revised by Andrew Crossman at BDO, with the support of the firm's expert property tax team.

The book is divided into the four categories of property ownership: property investors; property dealers and developers; trading premises and private residences. Within each category all relevant tax planning areas are outlined chapter by chapter, with reference to legislation and case law.

Newly updated, as of Finance (No.3) Bill 2017 - 2019, to include:

Commentary on income received by non-UK resident companies from UK property rentals being chargeable to corporation tax, rather than income tax, from 6 April 2020

Non-resident capital gains on any UK immovable property (and land-rich companies), being subject to tax from 6 April 2019 and the impact on widely-used structures

Also includes the following:

Changes to the substantial shareholding exemption

Changes to capital allowances legislation

Carry forward loss rules/changes to group relief

The effective replacement of the worldwide debt cap with the Corporate Interest Restriction rules from 1 April 2017

Commentary on the hybrid rules that can entirely prevent tax deductions for financing costs

Changes to trading in land and transactions in land anti-avoidance provisions

Commentary around avoidance practices and HMRC success in 2016 and 2017 with reference to case law.