You can also just liquidate the offshore company, with the distribution of the UK properties going to the shareholders. This should be treated as capital distributions and so subject to UK CGT. As there wouldn’t be any consideration payable for the properties, there shouldn’t be any SDLT issues. The properties would now be held in the hands of the individuals and so any income or disposals made by those individuals, would be subject to UK tax.

The following does not constitute advice, but rather demonstrate that there are options available to you should you wish to bring UK property back to the UK. Each case would need to be reviewed to see which option is best. If this is an area you would like advice on, please do get in touch.

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