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Property investment: some recent developments

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Tax has always been important to UK property investment structures, but the landscape has changed appreciably in recent years. Significant developments include the corporate interest restriction and anti-hybrid rules, which can substantially impair the ability of companies within a UK property investment structure to obtain tax deductions for interest expense, as well as the non-resident capital gains tax regime, which will influence exit planning for investors and even the vehicle through which investors choose to invest. In addition, the recent consultation on the taxation of asset holding companies seems to presage further change to this area, which rarely remains static for long.

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