In recent years, the government has pared down the benefits of offshore structures considerably in line with growing anti-avoidance sentiment. Thomas Adcock, tax partner at accountancy firm CBW, explores whether these structures are still useful to investors when those that hold UK residential property have lost most of their UK tax benefits.

Until recently, it was standard planning for a UK resident non-dom to acquire UK property via an offshore company held by an offshore trust settled by them for the benefit of their family. The property could be enjoyed by all whilst any gain on its sale was sheltered from HMRC as well as exempted from their estate for the purposes of inheritance tax (IHT).

Whilst extensive anti-avoidance legislation attacks such structures, these measures are mostly toothless tigers when applied to UK resident non-doms who hold investment assets via such structures. But oh, how "the times they are a-changin'".

The government began reinforcing its attack on offshore structures in April 2012, when it introduced a punitive Stamp Duty rate of 15% for high value properties worth more than £2m when acquired by a company. This was followed 12 months later by the Annual Tax on Enveloped Dwellings (ATED), a wealth tax based on the market value of the property held by such a company as well as bringing such structures within the charge of UK Capital Gains Tax (CGT) where the property is caught by the ATED regime. In April this year, non-residents who were previously exempt from CGT were brought within the charge of UK CGT where they disposed of UK residential property that was not caught by ATED.