Tax weekly highlights—29 May 2025
This week's edition of Tax weekly highlights includes: (1) updates to HMRC’s DOTAS guidance, (2...
Tax is a key consideration when selecting an appropriate structure for holding UK property, together with all relevant commercial and other legal considerations. The tax treatment of a particular structure should always be considered in conjunction with the following factors:
the tax profiles of the ultimate owners—where they are resident, if they are companies or individuals etc, and
whether the UK property is to be held as an investment or an item of trading stock
This sub-topic covers the tax treatment of the most common structures for holding UK real estate, including:
corporate structures
partnership structures
offshore unauthorised property unit trust structures (eg JPUTs), and
contractual joint ownership structures
The Practice Notes in this sub-topic focus primarily on the direct tax (ie corporation tax, income tax and CGT) treatment of these holding structures. In this overview, CGT means both capital gains tax and corporation tax on chargeable gains save where expressly specified. Where appropriate, the annual tax on enveloped dwellings (ATED) is discussed. For further details on ATED, see our ATED subtopic.
The indirect tax ...
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