Mitigating SDLT continues to drive UK property acquisition structures. Purchasing a property owning vehicle is often the preferred route. Most JPUTs now fall outside the offshore funds tax regime, but offshore companies with fixed lives may fall within it. It is sometimes possible for a buyer to save SDLT by buying a UK company and also uplift the base cost of the property. Care needs to be taken to avoid tax charges arising on debt releases on the purchase of a distressed UK property company. Disapplication of the buyer’s VAT option to tax is still a potential issue in some cases.
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