Traditionally, the focus of real estate taxation has been on indirect taxes, such as stamp duty land tax (SDLT) and VAT.
The corporatisation of the real estate market and the increased use of joint ventures and alternative vehicles such as unit trusts, limited partnerships and LLPs for both investment and development transactions, requires a range of expertise that extends beyond indirect taxation and covers both direct and international taxation. Our Corporate Tax group has wide ranging experience of these more complex structures and the interaction between real estate, corporate and private taxation.
Much of our real estate tax work has an international element, with a specific focus on inward investment and the financing of investment and development projects in the UK. Our Luxembourg office has extensive experience of advising on the use of Luxembourg companies and funds as tax efficient vehicles for holding, and financing, UK and European real estate portfolios.
Our clients include investment funds, offshore investors and blue chip financial institutions ranging from major retail banks to insurance companies.
Corporate structures for real estate investment - UK and Luxembourg
Advising on the establishment of a range of UK and Luxembourg vehicles to own and develop UK real estate, including limited partnerships, unit trusts and fund vehicles.
Property development joint ventures
Advised on numerous property development joint ventures, including corporate partnership and contractual JVs; SDLT mitigation structures, transfer pricing issues, and general consortium relief and VAT grouping issues. These range from joint ventures in the house-building sector to site assembly transactions and collaboration and profit sharing agreements between multiple landowners.
Advising a leading overseas nursing home investor on the tax efficient structuring of its funding arrangements, and the restructuring of its debt facilities.
Indirect tax advice
Advising one of the UK's leading financial institutions with regard to new headquarters office buildings, and in particular on the detailed application of the VAT anti-avoidance legislation to partially exempt financial institutions.