Yesterday, 30 October 2024, the Chancellor announced that the Autumn 2024 budget will raise taxes by £40bn, the biggest raise since 1993. While the Autumn budget arguably does not portray as pessimistic an outlook for...more
11/1/2024
/ Autumn Statement ,
Budgets ,
Business Taxes ,
Capital Gains ,
Capital Gains Tax ,
Carried Interest ,
Carried Interest Tax Rates ,
Corporate Taxes ,
Inheritance ,
Inheritance Tax ,
Stamp Duty Land Tax ,
Tax Rates ,
UK
The real estate sector was not ignored by Budget announcements today. There were no seismic changes – the changes announced were less impactful than the speculation in the weeks preceding the Budget....more
10/31/2024
/ Autumn Statement ,
Budgets ,
Business Taxes ,
Capital Gains ,
Capital Gains Tax ,
Carried Interest ,
Carried Interest Tax Rates ,
Consultation ,
Corporate Taxes ,
Investment Funds ,
Residential Property Owners ,
Stamp Duty Land Tax ,
Tax Rates ,
UK
Budgets are normally stories of two halves. The first half contains the headline-grabbing tax policy reforms that can be encapsulated in a snappy soundbite in the Budget speech, such as “Chancellor scraps the non-dom regime”....more
3/1/2024
/ Autumn Statement ,
Compliance ,
Corporate Taxes ,
Estate Tax ,
Federal Budget ,
First Time Homebuyers ,
General Elections ,
Gift Tax ,
HMRC ,
Income Taxes ,
Revenue Growth ,
Stamp Duty Land Tax ,
Tax Incentives ,
Tax Levy ,
Tax Reform ,
UK ,
Value-Added Tax (VAT)
In contrast to recent years, when there has been plenty for real estate tax lawyers to feast on, this Autumn Statement was fairly quiet.
Full expensing -
After a prolonged period of time-limited, enhanced reliefs,...more
The Government has announced a further series of proposed changes to the UK REIT rules as part of the wider review of the UK funds regime and published draft legislation.
This third set of changes are earmarked for...more
Underneath the headline points, the Budget contained a number of measures designed to fulfil the Chancellor’s objective of encouraging growth and investment. There was broadly good news for those investing in UK real estate....more
3/20/2023
/ Budgets ,
HMRC ,
Interest Rates ,
Investment Funds ,
Real Estate Investments ,
Real Estate Market ,
REIT ,
Sovereign Wealth Funds ,
Spring Statement ,
Tax Deductions ,
Tax Rates ,
UK ,
Value-Added Tax (VAT)
Some of the most commonly used trust structures in UK real estate ownership are Jersey Property Unit Trusts (JPUTs). It has become clear recently, following confirmation from HMRC, and HMRC now changing its published...more
The changes to the Luxembourg-UK treaty will not be effective until 2024 at the earliest because Luxembourg did not ratify the treaty changes in 2022. The delay was expected, as trailed in our earlier blog, where we explore...more
Unexpectedly, it is likely the changes to the Luxembourg-UK double tax treaty will not be effective until 2024 at the earliest. Where that is the case, some Luxembourg investors in UK property rich entities will have another...more
In an attempt to calm the markets and ensure the UK’s economic stability the new Chancellor, Jeremy Hunt, gave a statement ahead of the scheduled Medium-Term Fiscal Plan on 31 October.
He announced a reversal of almost...more
Summary -
Some key measures for businesses in this sector were:
..Cancellation of the planned increase in the rate of corporation tax from 19% to 25% from April 2023. The rate will remain at 19%.
..From November...more
The UK government is consulting on bringing overseas sovereign investors in UK real estate within the scope of UK direct tax from April 2024 as part of measures amending the scope of the sovereign immunity tax exemption. ...more
The UK and Luxembourg have renegotiated their double tax treaty. The new treaty has been published, but is not yet in force. Significant changes have been made to the capital gains tax article amongst other provisions....more
On 10 February 2022 HM Treasury published a response document (Response) to its January 2021 ‘call for input’ on a review of the UK funds regime. The review was necessarily wide-ranging, covering direct and indirect tax,...more
The government is proposing to change the way SDLT is calculated on mixed-property purchases (where residential and non-residential elements are acquired) and on the scope of multiple dwellings relief (MDR). It is offering a...more
It was a relatively light Budget for the real estate sector. Highlights included the long-awaited announcement of the rate of the residential property developer tax and some reform of business rates....more
10/28/2021
/ Autumn Statement ,
Business Taxes ,
Capital Gains ,
Consultation ,
Investment Funds ,
Popular ,
Property Owners ,
Property Tax ,
Real Estate Development ,
REIT ,
Residential Property Owners ,
Stamp Duty Land Tax ,
Tax Rates ,
UK ,
Value-Added Tax (VAT)
In this blog we consider the current design of the residential property developer tax (RPDT). Separately we have blogged on the triggers for liability. This blog is based on the current draft of the legislation issued on 20...more
This is likely to be a key reflection when considering the details issued in July about the new UK holding company regime for “qualifying asset holding companies” (QAHCs). The new regime is intended to make the UK more...more
As part of an initiative to promote UK funds the government is proposing a beneficial new tax regime for asset holding companies (AHC) in investment fund structures. This is intended to make the UK a more competitive location...more
After the broad brush measures taken at the start of the COVID-19 crisis, UK Chancellor, Rishi Sunak, is now targeting help for some of the hardest hit sectors of the economy and is supporting jobs in particular. In his...more
In the light of COVID-19, HMRC has taken various measures which modify the UK’s taxation system. This blog post summarises the changes which UK taxpayers should be aware of, and the tax implications of various other measures...more
This briefing summarises the key announcements in the Spring Budget from a funds perspective: including the UK funds review, the SDLT surcharge for corporate and individual non-resident purchasers of UK residential property...more
3/18/2020
/ Federal Budget ,
Financial Conduct Authority (FCA) ,
Financial Services Industry ,
Fund Managers ,
Holding Companies ,
Investment Funds ,
OFR ,
Private Placements ,
Real Estate Investments ,
Residential Property Owners ,
Surcharges ,
Tax Reform ,
UCITS ,
UK ,
Value-Added Tax (VAT)
In contrast to recent years it has been a quiet Budget for real estate tax. In particular, there was no big announcement of any further levelling of the playing field between resident and non-resident investors in UK land:...more
The Government has amended the existing non-resident landlord scheme regulations (S.I. 1995/2902) in readiness for the transition to corporation tax for non-resident corporate landlords from 6 April 2020. The changes impact...more
2/20/2020
/ Amended Regulation ,
Commercial Leases ,
Commercial Property Owners ,
Commercial Tenants ,
Corporate Taxes ,
HMRC ,
Real Estate Brokers ,
Real Estate Professionals ,
Tax Deductions ,
UK ,
Withholding Tax