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Our paper considers the progressive loss of UK tax benefits associated with offshore corporate ownership of UK residential property. The main attack comes from the ATED regime but there are some very satisfactory reliefs that arguably make ATED a voluntary tax.
The paper also reviews the possible advantage of selling the corporate envelope itself (i.e. a share sale). The downside risk for the buyer has made these arrangements rare in the past, but with SDLT rates at 15%, there is now more of an inducement for certain buyers to buy corporate envelopes where the target property is enveloped and the property’s value is substantial.