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Offshore companies owning UK residential property

New UK tax considerations in 2018

Martin Palmer’s article 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 article 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.

The article also summarises the BVI legal services that Jordans can now provide. Many UK properties are owned by BVI companies, and whether clients want to acquire a UK residential or commercial property via a BVI company, or de-envelope a UK property from a BVI company, Jordans can now provide the necessary BVI legal advice and BVI legal opinions for a wide range of property transactions, and other commercial transactions.


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 Martin Palmer

Martin Palmer
T: +44 (0)117 918 1321

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