Market leading insight for tax experts
View online issue

Ask an expert: A case study on de-enveloping

Speed read
Q: My clients a married couple who are UK resident and domiciled are proposing to purchase a BVI company (BVICo) whose sole asset is a freehold dwelling in London (‘the property’) valued at £6m. The purchase price for the BVICo shares will be £6m subject to adjustment so that the clients will acquire BVICo on a cash-free debt-free basis. The clients will fund the purchase price with their own cash. BVICo which is managed by its directors in Jersey purchased the property in 2010 for £2.5m with the aid of a mortgage of £2m which is still outstanding and which the seller will require to be discharged. BVICo has always used the property for lettings at arm’s length rents to unconnected tenants and the property’s value on 5th April 2015 was £5m. The tenants have agreed to vacate the property prior to completion...

If you or your firm subscribes to Taxjournal.com, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
EDITOR'S PICKstar
Top