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My client is UK domiciled and UK tax resident. He is thinking about acquiring a property in France as an investment to let it out.
His French lawyer has advised him to acquire the property through a société civile immobilière (SCI). According to his French lawyer such arrangements are common in France because of the domestic tax inheritance advantages.
According to the French lawyer the rental income that my client will receive will be taxed in France and subject to income tax. Although the SCI is in itself a ‘company’ the French lawyer confirmed that the SCI is regarded as ‘transparent’ from a French tax perspective and hence the income is taxed on the individual.
My first question is in respect of the UK tax treatment of this rental income. It appears from HMRC’s internal manual that an SCI is regarded as ‘opaque’ from a UK tax perspective and hence...
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