The article considers the extent to which investors in certain property fund vehicles that are transparent for tax on income are also treated as if they held underlying property directly for other UK taxes. The fund types are UK partnerships, offshore unit trust schemes and co-ownership authorised contractual schemes. The taxes concerned are SDLT, equivalent devolved taxes, CGT and, more briefly, capital allowances and VAT. Two case studies track the effect of introducing new money into existing structures. The article also notes the possible introduction of a new type of tax transparent property fund for professional investors.
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The article considers the extent to which investors in certain property fund vehicles that are transparent for tax on income are also treated as if they held underlying property directly for other UK taxes. The fund types are UK partnerships, offshore unit trust schemes and co-ownership authorised contractual schemes. The taxes concerned are SDLT, equivalent devolved taxes, CGT and, more briefly, capital allowances and VAT. Two case studies track the effect of introducing new money into existing structures. The article also notes the possible introduction of a new type of tax transparent property fund for professional investors.
If you are not a subscriber, subscribe now to read this content.
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