Capital Gains Tax and Investment Income


This update provides some background to and information about HMRC’s letters and some guidance to help members decide the most appropriate way to respond if a client receives one of the letters.

The CIOT response to the HMRC consultation on Private Residence Relief: changes to the ancillary reliefs.

HMRC has provided comments on the Q&As relating to rebasing and the adjustments to the CGT foreign capital losses election.

HMRC has provided comments on the Q&As relating to the extension of IHT to overseas property representing UK residential property interests.

This call for evidence seeks views on how SITR has been used since its introduction, and why its use has been lower than previously anticipated. 

The CIOT comments sent to HMT on the Stamp Duty Land Tax: non-UK resident surcharge consultation.

HMRC has provided comments on the Q&As relating to mixed fund cleansing. 

The CIOT comments on the the HMRC consultation The Taxation of Trusts: A Review.

The CIOT response to the HMRC call for evidence on Amendments to Tax Returns.

As we have previously reported, new rules for foreign domiciliaries and non-UK resident trusts were introduced from April 2017, by Finance (No 2) Act 2017 and Finance Act 2018. The rules contain anti-avoidance provisions but also protections to help settlors of offshore trusts affected by the changes. However, there is a technical defect in the legislation, relating to offshore income gains, which could cause serious problems.