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Purchase of property owning SPVs by a UK REIT group

Question

A UK REIT group wishes to purchase from a third party shares in a UK resident and a non-UK resident SPV each owning UK commercial property for investment purposes thereby avoiding SDLT and limiting UK stamp duty to 0.5% of the consideration payable for the purchase of shares in the UK resident SPV. The non-UK resident SPV will become UK resident on acquisition by the REIT group by reason of being managed and controlled in the UK. A completion balance sheet will be drawn up for each SPV to include provision for income tax or corporation tax liabilities up to the date of completion. Existing SPV debt will be partly refinanced at completion out of funds to be provided by a third party bank with additional funding to be provided out of the resources of the REIT group. The SPVs will incur substantial liabilities (break costs) as...

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