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Readers Forum: Liquidation proceeds

15 June 2021
Issue: 4796 / Categories: Forum & Feedback
Tax treatment of proceeds of land to non-resident.

My new client has provided me with details of income received by his infant grandchildren who are resident in Sweden in the past tax year.

The UK income is insignificant and the overseas income in the investment portfolio is not subject to UK income tax so I do not believe that there is a need for the children to submit a UK return.

However among the receipts are distributions from the family company that had owned land which the company sold in June 2019. The distributions under liquidation were made in the summer of 2020.

The land was the only asset of the company so would have been affected by the change in April 2019 to indirect holdings of land by non-residents. The legislation talks about assets ‘derived from’ UK property and goes on to say directly or indirectly so I am not...

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