Advice re duties payable in this scenario..?

[overweightlemon]

Hi there

Joe was born in UK but now works in and is a resident of Holland. Joe owns two properties in the UK that he rents out. Neither is his PPR.
Michael was born in UK but now works in and is a resident of Switzerland. Michael rents one of Joe's properties off him for occasional use..

Joe has offered Michael the opportunity to buy the flat. Joe has been advised by his UK accountant that selling the flat would attract CGT.


What tax liabilities arise in a situation where two people are each residents of foreign countries and are selling something that is an immovable part of the UK? (as opposed to michael buying joe's car, wherever it may be)
Is it a matter for the tax offices of each respective country, or do the UK tax office take an interest in houses specifically because they cannot be reasonably moved outside the border to be sold? Do house sales class as income generated in the UK? Does it make any difference that both people are settled and resident in other countries, neither of which have Capital Gains Tax (and many other, lower taxes)

Any pointers would be massively appreciated. Thanks!

[section 44]

Joe has been advised by his UK accountant that selling the flat would attract CGT.

At present, Joe would not be liable to UK CGT.

Do house sales class as income generated in the UK?

They can.

[maths]

Whether Joe is liable to UK CGT on a sale of UK property is dependent upon how long he was resident in the UK prior to departure and how long he remains non-resident for UK tax purposes.

House sales most unlikely to be treated as income as opposed to capital gains.