Property holding structures—SDLT and VAT treatment of a Jersey Property Unit Trust (JPUT)

The following Tax practice note provides comprehensive and up to date legal information covering:

  • Property holding structures—SDLT and VAT treatment of a Jersey Property Unit Trust (JPUT)
  • SDLT treatment of a JPUT
  • Deemed market value on transactions involving connected companies
  • No group, reconstruction or acquisition relief
  • SDLT seeding relief
  • Due diligence
  • SDRT on transfer of units
  • Stamp duty on transfer of units
  • VAT treatment of JPUTs in relation to supplies of land
  • Transfers of property to and from a JPUT—TOGC treatment
  • More...

Property holding structures—SDLT and VAT treatment of a Jersey Property Unit Trust (JPUT)

IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s withdrawal from the EU. At this point in time (referred to in UK law as ‘IP completion day’), key transitional arrangements come to an end and significant changes begin to take effect across the UK’s legal regime. This document contains guidance on subjects impacted by these changes. Before continuing your research, see Practice Note: What does IP completion day mean for Tax?

Some investors, particularly non-UK resident investors, may hold UK real estate 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 Jersey Property Unit Trusts (JPUTs) (since Jersey property unit trusts are common).

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. A different form of seeding relief was introduced by section

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