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The new UK fund vehicle Reserved Investor Fund (RIF) is available beginning today, 19 March 2025. The RIF is available for all investment strategies, but what might make it an appealing option, particularly certain tax...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
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
The UK Government’s public consultation on Asset Holding companies (AHCs) has just finished, having run from December 15, 2020 to February 23, 2021. The objectives of the UK Government in the consultation have been to improve...more
Non-UK resident investors (Investor) usually acquire UK commercial real estate (UK Property) through non-UK resident companies, for example Jersey limited liability companies. A typical holding structure put in place by an...more
On 6 July 2018, the UK Government published draft legislation to extend the territorial scope of UK tax by bringing capital gains realised by non-UK resident investors from UK real estate within the scope of UK taxation with...more
On 6 July 2018 the UK Finance Bill 2019 was published by the UK Government. The draft Finance Bill contains the details of the new regime on taxation of non-UK resident investors in UK real estate that had been proposed in a...more
Quietly, almost without any fanfare, a tax policy of more than 50 years designed to encourage overseas investment into UK real estate was reversed in the small print of the Budget. The announcement has provoked a storm across...more
The UK Government has announced in today’s Budget (22 November) that it is launching a consultation on extending the scope of UK tax on real estate. Currently, non-UK residents who are investors in UK land and buildings...more