Tax on offshore property developers

The tax position of offshore property developers will depend on how they structure their development activities. Property developers that develop property overseas, and who are UK resident will be subject to UK income tax on any profits generated. They would therefore need to translate the proceeds & costs into sterling and calculate the trading profits. NIC would also be an issue and they'd need to consider class 2 & 4 NIC. This assumes that the trade is carried out personally. If it was carried out via an offshore company they would need to assess whether the profits of the company could be attributed to UK shareholders under anti avoidance rules. If not, any dividends or other income extracted from the company would be likely to be subject to UK income tax. If the property developers are based overseas and are developing UK property they would need to assess whether there was a UK trade or not. If there wasn't they may be able to avoid UK tax on the trade. Alternatively they could look to establish the activity as a UK investment activity and avoid CGT on the disposal by virtue of their non residence status.