From 5 April 2019, as part of legislative reforms to place non-residents and UK residents on a level playing field when purchasing property, non-resident investors will pay capital gains tax (CGT) on disposals of all UK property, rather than just on residential property as from 5 April 2015.

Usefully, for non-resident commercial property owners, the property acquisition cost can be rebased to 5 April 2019. Non-residents holding residential property can rebase the value to 5 April 2015, and many properties, particularly those in prime markets, are standing at a loss. It is therefore a very good time to look at existing structures, and to discuss future structures for the next deal.