josh.baker14 Baker
Joined: 10/1/2024
-
Greek resident and UK capital gains tax
The Greece/UK DTA of 1953 states - A resident of one of the territories who does not carry on a trade or business in the other territory through a permanent establishment situated therein shall be exempt in that other territory from any tax on gains from the sale, transfer or exchange of capital assets. We have a Greek Resident client selling UK residential property, is he still subject to UK CGT under the non-residence rules or is it overridden by the above and he is not subject to UK tax at all? Or instead is the treaty overridden by capital gains tax rules which came in even later.