Property holding structures

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Practice notes
SDLT—deeds of rectificationStamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from...
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19th May
Practice notes
VAT—triangulationIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 19th May
Practice notes
How employment income is taxed—non-cash earnings or benefitsIn addition to cash earnings, such as wages or salaries, many reward packages include...
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19th May
Practice notes
UK Crown Dependency/Overseas Territory Agreements (CDOT)—FAQsWhat are the CDOT agreements?The UK entered into agreements with its three Crown...
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Produced in partnership with Ali Kazimi of Hansuke 19th May
Practice notes
Key tax consequences of an insolvent liquidationThis Practice Note outlines:•the main corporation tax consequences when a UK incorporated company...
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Produced in partnership with Julia Fox of Deloitte LLP and Anthony Davis 19th May
Practice notes
EIS—deferred gain becomes chargeable to CGTCoronavirus (COVID-19): In response to the coronavirus (COVID-19) pandemic, the government introduced a...
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19th May
Practice notes
Corporation tax—connected personsThis Practice Note looks at the meaning of connected persons within sections 1122 and 1123 of the Corporation Tax Act...
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19th May
Practice notes
VAT on composite suppliesSingle composite supplies vs multiple suppliesWhere a supply comprises a number of different elements with varying VAT...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 19th May
Practice notes
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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19th May
Practice notes
Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 19th May
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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19th May
Practice notes
Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
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19th May
Practice notes
The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
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19th May
Q&As
Corporate redomiciliation—can a non-UK company redomicile into the UK?It is possible for a non-UK incorporated company to redomicile to the UK....
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19th May
Practice notes
R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D)...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...
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19th May

Most recent Property holding structures content

Q&As
If a property development company buys a residential property, how does it demonstrate it should be charged normal SDLT rates instead of the 15 per...
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31st Jul
Q&As
Does the reference to 'contract' within section 44(10)(b) of the Finance Act 2003 cover an agreement which is not legally binding?SDLT is a tax on...
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31st Jul
Q&As
If a company is used to purchase a residential property located in England are there any other considerations to factor in over and above the usual...
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Produced in partnership with Chris Bryden of 4 King’s Bench Walk 31st Jul
Practice notes
Property holding structures—direct tax treatment of UK companyAlthough a buyer may have reasons to hold commercial and, sometimes, residential...
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Produced in partnership with Charles Goddard of Rosetta Tax 31st Jul
Practice notes
Property holding structures—direct tax and stamp taxes treatment of a non-UK companyOwners of UK property may choose to hold their property through a...
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Produced in partnership with Charles Goddard of Rosetta Tax 31st Jul
Practice notes
Vehicles for property development and investment—VAT implicationsThis Practice Note is about the VAT treatment of partnerships, joint ventures and...
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Produced in partnership with Martin Scammell 31st Jul
Practice notes
Key UK tax issues arising on the sale and purchase of an SPV owning UK commercial propertyTax is a key consideration when selecting an appropriate...
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Produced in partnership with James Meakin of Dentons 31st Jul
Practice notes
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...
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31st Jul
Practice notes
Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)STOP PRESS relating to property rich collective investment...
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31st Jul
Practice notes
Property holding structures—direct tax treatment of contractual joint ownershipThe simplest form of joint investment in property is for the investors...
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Produced in partnership with Charles Goddard of Rosetta Tax 31st Jul
Practice notes
Property holding structures—direct tax treatment of a UK limited liability partnershipAlong with limited partnerships (LPs), limited liability...
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Produced in partnership with Charles Goddard of Rosetta Tax 30th Jul
Practice notes
Property holding structures—direct tax treatment of a UK limited partnershipPartnerships are often used as vehicles for holding UK real estate. The...
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Produced in partnership with Charles Goddard of Rosetta Tax 30th Jul

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