We are already aware that the protection from UK inheritance tax (IHT) with the use of a non UK company to hold UK residential property will be removed. However it does trigger the need to question the overall costs versus the benefit of such a company.

Where ATED is charged and no IHT protection is available, it is likely that, for some at least, deenveloping will be a real possibility. For others the cost of the ATED charge may be acceptable and it is important to consider all the facts and individual circumstances before making a long term decision.