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...

Owner-occupied UK residential property held through offshore companies: SDLT/ATED, corporation tax and CGT, IHT including FA 2025 residence-based changes, and practical compliance issues

Published by a LexisNexis Private Client expert

Practice notes

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

Finance Act 2025 (FA 2025), which gained Royal Assent on 20 March 2025, enacts the abolition of the remittance basis of taxation and introduces a residence-based system from 6 April 2025. FA 2025 also removes domicile as the principal test when determining liability to inheritance tax.

Other updates include:

amendments to the rules that set excluded property status,
abolition of the protected settlements status for offshore trusts,
modifications to overseas workday relief.

For analysis of these measures, 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.

This Practice Note explains the tax position of individuals who own a UK residential property, used as a home, through an offshore Company. It does not address Ownership of UK residential property via an offshore company for any alternative purpose (eg investment or development). For guidance on those topics, see Practice Note: Property holding structures—direct tax and stamp taxes treatment of a non-UK company and as referenced above within the Practice Note cited here...

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Alison Cartin

Taylor Wessing LLP

Alison is a Knowledge Development Lawyer for the Private Client Group, responsible for the team's know how and training needs and monitoring legal and market developments. She regularly leads both in-house and external client training events and writes materials for the Bryan Cave Leighton Paisner Tax blog and clients. Prior to becoming a Knowledge Development Lawyer in 2004, Alison advised high net worth individuals and the international wealth management institutions that serve them on the full spectrum of contentious and non-contentious private client issues. She has extensive experience advising on cross-border tax and wealth planning issues and has been involved in advising governmental and regulatory bodies on the cross-border exchange of information in tax matters and international tax agreements. She is a member of the Society of Trust & Estate Practitioners (STEP)....

Web page updated on 27/05/2026

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