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GLOSSARY

Jersey property unit trust (JPUT) definition

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What does Jersey property unit trust (JPUT) mean?

This is a property holding trust. The key features are: • they are constituted by trust instruments under Jersey law • the legal person or persons are the trustees, ie the persons who will enter into documents as the property owner • the trust fund comprises the capital assets, eg the property, but does not include the income earned for the property • the entitlement of the beneficiaries of the trust is unitised, meaning that investors own securities (units) which are transferable and which represent an entitlement in the trust fund • a register is maintained in Jersey of each unitholder’s number and class of units in the same way that a share register is maintained for a company—the register is not public

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Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)

Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT) UK real estate can be held as an investment through an offshore unauthorised property unit trust. Such unit trusts are commonly established in one of the Channel Islands (typically, Jersey or Guernsey) or the Isle of Man, but may be established under the law of another non-UK jurisdiction. This Practice Note refers to such property unit trusts, wherever established, as JPUTs (since Jersey property unit trusts are common). It is assumed for the purposes of this Practice Note that UK real estate is held by a JPUT as an investment rather than an item of trading stock. For details of this distinction, see Practice Note: Dealing in property or property investment? JPUTs were popular historically because it used to be possible to transfer UK real estate to a JPUT free from stamp duty land tax (SDLT). This was pursuant to a specific exemption known as 'seeding relief', which was abolished from 22 March 2006. When in...

Sukuk—investment bond arrangements and UK VAT

Sukuk—investment bond arrangements and UK VAT This Practice Note outlines the UK VAT treatment of the issue of a sakk by an issuer to an investor (or sakk holder). A sakk is a certificate that confers certain rights on the holder to receive payments from time to time. Its key characteristics are comparable to those of a bond (or similar financial instrument). ‘Sukuk’ is the plural of ‘sakk’. A sukuk issuance is a form of Islamic financing. For more information on Islamic financing generally, see Practice Note: Key principles of Islamic finance. For more information on other (non-VAT) tax aspects of sukuk, see Practice Notes: Sukuk—investment bond arrangements and their UK direct tax treatment, Sukuk—investment bond arrangements and stamp duty and SDRT and Sukuk al ijara—tax reliefs for sale and leaseback arrangements. This Practice Note is written on the assumption that: • the issuer is a corporate special purpose vehicle • both the issuer and the sakk holder belong in the UK for VAT purposes in relation...

Discover our 8 Practice Notes on Jersey property unit trust (JPUT)