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For many years businesses have relied upon “offshore” or non-resident structures to reduce or defer taxes and improve returns for their investors. How these structures are managed may, however, be taking a different turn. Tax authorities seem to be asking whether there is a business reason to set up a company in another jurisdiction.
The Isle of Man is situated in the middle of the Irish Sea and is approximately 32 miles long by 12 miles wide with a population of almost 86,000 people. The Island is not part of either Great Britain or the UK but is known as a “Crown Dependency”. It is self-governing and is independent in all matters except for foreign relations and defence. The Head of State is the Queen who holds the title “Lord of Mann”.
I’ve written before about the various new tax regimes that have come out of HMRC since 2012 specifically targeting UK real estate. It started in 2013 with Annual Tax Enveloped Dwellings (“ATED”) and a new capital gains tax system for high value residential property. This was followed by the introduction of non-resident capital gains tax on all UK residential properties and most recently, the inclusion of all UK residential property, however owned, within the inheritance tax regime.