Robert Kent tax partner and Peter Cosmetatos senior associate of Freshfields Bruckhaus Deringer discuss the use of offshore unit trusts as vehicles for holding UK real estate
Ever since FA 2004 imposed a harsh stamp duty land tax (SDLT) regime on partnerships the previous vehicle of choice for collective investment in UK land there has been a trend towards holding UK land through unit trust arrangements. For a variety of reasons mostly relating to the problematic direct tax consequences of holding land in a UK unit trust whether authorised or unauthorised interest has focused on offshore unit trusts (OUTs).
OUTs are an attractive land-holding vehicle from an SDLT perspective mainly because of their treatment as deemed companies for SDLT purposes....
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Robert Kent tax partner and Peter Cosmetatos senior associate of Freshfields Bruckhaus Deringer discuss the use of offshore unit trusts as vehicles for holding UK real estate
Ever since FA 2004 imposed a harsh stamp duty land tax (SDLT) regime on partnerships the previous vehicle of choice for collective investment in UK land there has been a trend towards holding UK land through unit trust arrangements. For a variety of reasons mostly relating to the problematic direct tax consequences of holding land in a UK unit trust whether authorised or unauthorised interest has focused on offshore unit trusts (OUTs).
OUTs are an attractive land-holding vehicle from an SDLT perspective mainly because of their treatment as deemed companies for SDLT purposes....
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