Powered by Lexis+®
Jurisdiction(s):
United Kingdom
Related legal acts
Key definition
Ownership definition

What does Ownership mean? In legal practice, ownership describes who has the bundle of rights over property: to possess, use, enjoy income, exclude others, transfer, or charge it, subject to law and third‑party rights (such as easements/servitudes, leases and security interests). It is a descriptive expression used across contexts (land, goods, shares, intellectual property), rather than a single statutory definition, though related concepts are defined in legislation and case law (for example, beneficial ownership in anti‑money laundering/PSC regimes and land registration rules). Across England & Wales, Northern Ireland and Ireland, lawyers commonly distinguish legal ownership (title shown on a register, deed or share register) from...

Read More Right Arrow

UK residential property for offshore clients: structuring choices, tax exposure (IHT, CGT, SDLT/LBTT/LTT, ATED), and the Finance Act 2025 residence-based IHT reforms

Practice notes
imgtext

STOP PRESS: Abolition of non-dom regime and introduction of residence-based IHT regime

Finance Act 2025 (FA 2025), which received Royal Assent on 20 March 2025, brings in legislation to end the remittance basis of taxation and introduce a residence-based approach from 6 April 2025. It also makes residence, rather than domicile, the principal test for Inheritance tax exposure. Additional reforms include updates to the rules on excluded property status, the removal of protected settlements status for offshore trusts, and revisions to overseas workday relief. For further detail, see Practice Notes: The abolition of the remittance basis of taxation from 2025–26 and A new residence-based regime for IHT from 2025–26. See also: Finance Bill Tracking Service: Key dates (Finance Bill 2025) and Finance Act 2025.

Who is an ‘offshore client’?

This Practice Note examines typical Ownership arrangements for UK residential property for offshore clients intending to use the property as a UK home. ‘Offshore clients’ refers to individuals who:

  • up to 5 April 2025, are non-UK domiciled and not deemed UK domiciled for UK tax purposes; and
  • from 6 April 2025, will not be long-term UK resident for inheritance tax (IHT) purposes—see Practice...
To view the latest version of this document and thousands of others like it, sign-in with LexisNexis or register for a free trial.
Web page updated on 22/05/2026

Popular documents

When evaluating a general damages claim, the practitioner ought initially to refer to the Judicial College Guidelines (JCG)...

Read More Right Arrow

This Practice Note This Practice Note reviews mechanisms used in settling litigation. A Tomlin order consists of a consent order paired with a schedule. It operates to stay proceedings on terms that have been agreed. The provisions contained in the schedule may remain confidential. This Practice Note describes the scope of confidentiality attaching to the schedule and sets out how it differs from a standard consent order. Sample wording for a Tomlin order is included, alongside links to precedents, as well as guidance on court approval. It also addresses varying, setting aside and enforcing a Tomlin order, including the considerations the court will take into account when handling applications for each. Further guidance is provided on interpreting and applying the relevant provisions of the CPR; however, some courts and divisions impose very specific requirements for both drafting and approval, and for approaching the schedule and confidentiality issues. Accordingly, you must consider the particular rules and court guide provisions in the forum where your claim is proceeding when drawing up the Tomlin order...

Read More Right Arrow

Date [ date ] Parties [ name of Landlord ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Landlord) [ name of Tenant ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Tenant) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Guarantor) ] [ [ name of Mortgagee ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Mortgagee) ] Definitions Within this Deed, the terms below shall be interpreted as follows: [ Annual Rent • the annual sum reserved under the Lease; ] [ Insurance Rent • the Tenant’s share of the Landlord’s costs of insuring the Property (as set out in the Lease); ] Lease • the lease of the Property dated [ date ], entered into between (1) [ the Landlord OR [ name ...

Read More Right Arrow

I, [ name ], of [ address ], solemnly and sincerely state that: [ Matters to be verified, set out in numbered paragraphs ] I make this solemn statement in good conscience, believing it to be true, and pursuant to the provisions of the Statutory Declarations Act 1835. DECLARED at [ details ] this [ day ] day of [ month and year ] Before me ................................................................................ [ signature of the person before whom the declaration is made ] A [ commissioner for oaths OR [ solicitor OR [ insert other qualification ] ] authorised to administer oaths ]...

Read More Right Arrow