The British Virgin Islands (BVI) has committed to creating a publicly accessible register of company ownership by 2023. Is Private Eye celebrating? In September 2015, it created an easily accessible online map of properties in England and Wales owned by offshore companies, and provided a link for readers to submit any additional information they might have about these properties.
On a more serious note, offshore companies are now broadly subject to tax on rental income on the same basis as UK tax resident companies, the comprehensive non-resident capital gains tax regime is in place since April 2019, and the advantages for inheritance tax (IHT) purposes of holding UK residential property through a non-UK entity have been removed. As such, some investors may wonder whether it is simply easier to own a property though a special purpose vehicle (SPV) incorporated in their home jurisdiction (and thus save on the directors and other fees charged by the BVI advisors, and associated administrative burdens).
This announcement may, alternatively, lead to an increase in onshoring i.e. using a UK holding vehicle, although this is likely to be appropriate predominantly for investments in UK residential property, as IHT is still a relevant consideration for individuals who indirectly own commercial property.
The British Virgin Islands (BVI) has committed itself to creating a publicly accessible register of company ownership by 2023 in a move welcomed by the UK government.