Our client is a successful trading company (Tradeco). It has outgrown its existing rented trading premises and is considering purchasing a freehold property which it will do using a mix of its own cash and bank funding. The property is larger than it needs for its requirements so approximately half the building will be let to a third party. The company is owned 50:50 by Mr X and his wife who also works in the business. What options are available for structuring the purchase?
Historically there has been a driver to hold investment property outside a UK corporate because of the low CGT rates for individuals. With the CGT rate at 28% and the corporation tax rate at...