Equiom CI seminars highlight new UK tax rules

Monday 19 February 2018

More than 100 guests and members of the business community gathered to hear presentations by tax experts from Equiom Solutions at two separate seminars, in Jersey at the Pomme d’Or Hotel, St Helier and in Guernsey at the Old Government House Hotel, St Peter Port.

Speakers covered topics including tax planning for Channel Islands residents, the proposed new rules regarding UK commercial and residential property and planning using ‘protected’ trusts.

The event in Jersey was opened by Head of Business Development - Europe, Richard Tribe and in Guernsey by Legal Director, Marcel Cariou. It began with a presentation by Senior Tax Consultant Glenn Cassidy who addressed the topic of investing in UK property and the new tax rules which now apply to non-resident individuals, companies and trusts.

‘From April 2017, shareholders of non-UK corporate entities holding UK residential property will be exposed to inheritance tax (IHT). Two consultation documents were also released by HMRC in 2017 concerning further amendments to the taxation of non-UK companies holding UK property. The first explores the proposed charge to UK Corporation Tax on non-UK resident companies holding UK property and is expected to come into effect from April 2020. The second concerns the charge to Capital Gains Tax (CGT) on gains realised by non-residents on disposals of UK commercial property including the proposed CGT charge on the disposal of indirect holdings of all UK property, effective from April 2019. Although these are only proposals and are out for consultation, it is likely that they will be enacted and as a result it is advisable to reassess how your UK property assets are structured ahead of April 2019.’

Equiom Solutions Managing Director, Helen Woods then discussed UK tax planning for Channel Islands residents. Helen highlighted an issue around those individuals with a UK domicile of origin who were born in the UK and have acquired a domicile of choice in the Channel Islands. Helen explained that if these individuals become UK resident at a later date, even for a comparatively short period of time, this will have adverse tax consequences. Helen went on to outline some planning opportunities, and explained the new deemed domicile rules effective 5 April 2017, that impose non-UK domiciled individuals who are resident in the UK for more than 15 years deemed domicile status for all UK taxes. Helen went on to explain there were substantial opportunities for non-UK domiciled individuals and expert advice should be sought.

‘The new rules present both challenges and opportunities for long term non-UK domiciled individuals resident in the UK including any structures created.’

The seminars concluded with a Q&A session and closing remarks from Richard Tribe and Marcel Cariou.


Equiom Solutions provides tax and estate planning services to Isle of Man residents and businesses. The highly qualified and experienced team offers tax and estate planning advice and help with annual tax obligations, as well as outsourced tax compliance services for fiduciaries. For more information, visit www.equiomgroup.com/tax