In these unprecedented times, Axiom Stone Solicitors will, in common with other businesses, be following the Government's official advice on social distancing and social isolating.

Public health measures must have the highest priority and, as a result, some staff will be working from home. Also, our offices will be closed to visitors.

However, we wish to reassure existing and potential clients that we will continue to provide the highest levels of service.

Please be assured we have a robust business continuity plan in place that is designed to minimise the impact on our service to you.

In addition, please continue to contact us electronically or by phone in relation to the progress of your matters or on any issues of concern to you.

Until further notice, service of claim forms, application notices and all other court documents and contractual notices must be made to our head office only (we shall not accept service through any other means). Our head office address is at Axiom Stone Solicitors, Axiom House, 1 Spring Villa Road, Edgware, Middlesex, HA8 7EB. We ask that all other correspondence be sent by email to the relevant member of Axiom Stone Solicitors. In the event that service of court documents or contractual notices is attempted by post, courier, DX, or fax to any address other than that of our Head Office, we cannot provide any assurance that they will be received or processed. We are grateful for your understanding at this time.

We will update this information regularly on our website (Please see COVID-19 Updates Here) and via social media.

Finally, we urge everybody to follow the official advice on fighting the virus outbreak so enabling you to stay safe and well.

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Holding UK property in an overseas company used to be practical & popular planning for non-domiciled individuals for IHT purposes

Historically, by holding UK residential property in an off-shore company, a non-domiciled/non-deemed domiciled individual ensured that the property was not included in his estate for inheritance tax purposes. Non-UK domiciled individuals previously only paid inheritance tax on UK real property. By holding the UK residential property via an offshore company, the assets the individual held are shares in an offshore company – i.e. not a UK situated asset. Company shares were often placed into trust, especially if there was a future danger of the individual (re)gaining UK domicile or deemed domicile.

This was standard tax planning for a non-domiciled individual. The treasury were fully aware of it and allowed it to continue for many years… until now. It was one of the reasons why the UK was so attractive to wealthy international investors (together with historically favourable CGT treatment among others).

Schedule 10, Finance (No. 2) Act 2017 ended the IHT protection gained by non-domiciled inviduals holding UK residential property via offshore companies in 6 April 2017. To the extent that the value of shares in such companies is attributable to UK residential property, the shares are not excluded property and they will form part of the estate for UK IHT purposes. From an IHT point of view, there is now no practical difference between holding a UK property directly or holding via an offshore company.

When recent changes to Capital Gains Tax and Stamp Duty are factored in, together with ATED, use of offshore companies for this purpose are pretty much over and done with.

Article by Vassos Vassou