Question 2ci
Your manager has been advising a client, Waverley, on his plans to sell his business. An email from your manager setting out the current situation and some notes on the tax system in the country of Surferia are set out below:
Email from your manager – dated 8 September 2016
Waverley
Waverley was born in 1976. He divorced his wife in 2014. His three children, all of whom are under 18, live with his ex-wife in the UK.
Residence status
Waverley has always been resident and domiciled in the UK, but it is likely to be beneficial for him to be non-UK resident for the tax year 2017/18.
Investment property
Waverley owns an investment property located in the UK. The property is a residential house, which is tenanted under a lease which expires on 31 October 2021. This house has never been Waverley’s principal private residence and it is not available for him to use. Waverley plans to sell this house as soon as possible following the end of the lease. He will then give the proceeds from the sale to his sister
Email from your manager – dated 8 September 2016
Please carry out the following work:
(c) Investment property
– Explain the capital gains tax implications in the tax year 2021/22 of the sale of the investment property, assuming that it gives rise to a chargeable gain and that Waverley is resident only in the country of Surferia in that tax year.
Tax manager
Notes on the tax system in the country of Surferia
– Individuals who are resident in Surferia are subject to capital gains tax on disposals of worldwide assets at the rate of 12%. There is no annual exempt amount.
– For the purposes of capital gains tax in Surferia, Waverley’s chargeable gains will be the same as they would be in the UK.
– The payment date for capital gains tax in Surferia is the same as the payment date for capital gains tax in the UK.
– There is no inheritance tax in Surferia.
– There is a double tax treaty between the UK and Surferia.
Required: Carry out the work requested in the email from your manager.
(c) Investment property.