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Ask an expert: Tax on offshore property investment company holding

Question

My client is an offshore property investment company acquiring a mixed use property in an expensive area in London. The property contains retail and office space and also a number of residential flats which are currently subject to assured shorthold tenancies. One of the flats has a market value in excess of £2m. My client has asked whether the 15% SDLT rate will apply in respect of part of the chargeable consideration payable for the property and the basis on which the SDLT return should be prepared. My client has also asked whether it would be subject to the new annual residential property tax (ARPT) and CGT on an ultimate disposal and if so what should be done to mitigate this.

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