"AREF welcomes the release today of the Technical Note, and associated clauses within the Finance Bill, to incorporate the special regime for collective investment vehicles investing in UK property within the wider non-resident capital gains tax rules. These measures should ensure that the tax will be appropriately targeted and should not result in CGT being imposed at multiple levels within investment structures or indirectly imposed on exempt investors such as UK pension schemes, if they invest through collective investment vehicles. The rules take into account a wide range of investment vehicles which are used for investing in UK property. While there remain some practical issues still to be resolved, in particular the reporting and optional withholding regimes which are to be implemented later in regulations, the AREF Tax Committee, which represented members through HMRC technical working groups, thanks the HMRC Policy team for listening to the industry’s concerns and for implementing, based on extensive, open and collaborative dialogue, a practical solution to the issues raised."
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