Property holding structures

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Practice notes
Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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Produced in partnership with Martin Wilson 9th Nov
Practice notes
It is market practice for a tax covenant, also known as a tax deed, to form part of the transaction documents in respect of a sale of all the shares...
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9th Nov
Practice notes
The reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are described in Practice Notes:...
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Produced in partnership with Zoe Feller of Bird & Bird 9th Nov
Practice notes
This Practice Note describes the law and practice relating to elections under section 198 or 199 of the Capital Allowances Act 2001 (CAA 2001), which...
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Produced in partnership with Martin Wilson 9th Nov
Practice notes
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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Produced in partnership with Eloise Walker of Pinsent Masons 9th Nov
Practice notes
This Practice Note is about the meaning of a scheme of reconstruction for tax purposes.Tax neutrality is maintained where a company (company A) enters...
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9th Nov
Practice notes
This Practice Note explains:•what a determination in respect of direct tax (ie a direct tax determination) is•when HMRC might issue a direct tax...
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Produced in partnership with Philip Rutherford 9th Nov
Practice notes
Where a dispute is brought to an end by a payment of damages or compensation, whether under a court order or an out-of-court settlement agreement:•the...
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9th Nov
Practice notes
A damages or compensation payment may attract VAT. This depends on exactly what the payment is for. If it is purely compensatory, it will be outside...
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9th Nov
Practice notes
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
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9th Nov
Practice notes
The Enterprise Investment Scheme (EIS) is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax...
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9th Nov
Practice notes
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
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Produced in partnership with Martin Shah 9th Nov
Practice notes
The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...
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9th Nov
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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9th Nov
Practice notes
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
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9th Nov
Practice notes
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
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9th Nov

Most recent Property holding structures content

Practice notes
FORTHCOMING CHANGE relating to property rich collective investment vehicles and certain investors: HMRC is consulting until 16 December 2020 on draft...
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4th Nov
Q&As
SDLT is a tax on land transactions (section 42(1) of the Finance Act 2003 (FA 2003)). A land transaction is an acquisition of a chargeable interest...
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28th Sep
Q&As
15% rate of SDLTFor details on the 15% rate of SDLT, see Practice Note: 15% rate of SDLT for high-value residential property transactions. See also,...
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28th Sep
Q&As
The process of purchasing residential property in England is broadly the same whether the purchaser is an individual or a limited company in terms of...
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Produced in partnership with Chris Bryden of 4 King’s Bench Walk 28th Sep
Practice notes
This Practice Note is about the VAT treatment of partnerships, joint ventures and other entities in the context of property development and...
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26th Sep
Practice notes
The simplest form of joint investment in property is for the investors to own the property jointly. While this is relatively rare in a commercial...
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26th Sep
Practice notes
FORTHCOMING CHANGE relating to SDLT for non-residents buying residential property: As announced at Budget 2018, confirmed at Spring Budget 2020 and...
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26th Sep
Practice notes
Some investors, particularly non-UK resident investors, may hold UK real estate as an investment through an offshore unauthorised property unit trust....
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25th Sep
Practice notes
Partnerships are often used as vehicles for holding UK real estate. The forms of partnership used are generally limited partnerships (LPs) and limited...
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Produced in partnership with Charles Goddard of Rosetta Tax 25th Sep
Practice notes
Along with limited partnerships (LPs), limited liability partnerships (LLPs) are used as vehicles for holding UK real estate.This Practice Note...
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Produced in partnership with Charles Goddard of Rosetta Tax 25th Sep
Practice notes
Tax is a key consideration when selecting an appropriate structure for holding UK commercial property. The most common form of investment in UK...
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25th Sep
Practice notes
Although a buyer may have reasons to hold commercial and, sometimes, residential property, via an offshore holding structure, the most common vehicle...
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25th Sep

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