Practice area: Real estate tax

Real estate tax

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Strategic tax advice at the outset can help to ensure that any transaction or restructuring runs smoothly and that there are no unplanned delays or forks in the road. Every corporate or real estate transaction comes with its unique tax implications. Our Tax team is dedicated to helping you optimise your structure with practical solutions to maximise allowances, mitigate liabilities, and ensure your tax affairs are in perfect order.

We provide strategic advice on property investment, development, finance, and funds, covering direct and indirect taxes like Stamp Duty Land Tax, and VAT, and business rates. Our clients range from institutional and private investors to developers and entrepreneurs, both in the UK and internationally. We collaborate closely with our Real Estate and Private Wealth teams from the outset.

When it comes to real estate strategy—whether acquiring, disposing, leasing, developing, constructing, or investing in commercial property—numerous tax issues arise. Our expertise in respect of property taxation covers:

  • VAT on purchases and development
  • Stamp Duty Land Tax on property acquisitions
  • Direct taxation on income, profits, or gains
  • Capital allowances to reduce taxable income
  • Structuring property ownership for investor attraction and tax-efficient exits
  • Bespoke property structures like REITs and PAIFs
  • Aligning corporate transactions with commercial objectives

We work closely with our colleagues in Private Wealth to ensure that innovative solutions are devised to ensure that the structure works efficiently from the Ultimate Beneficial Owner all the way to the lowest tier subsidiary.

In addition, Forsters’ Tax team is heavily involved with M&A matters, negotiating warranties and indemnities and W&I policies and analysing the availability of the substantial shareholding exemption for corporates and entrepreneurs’ relief for individuals.

Oliver Claridge

  • 29 August 2024

Oliver provides tax advice relating to commercial and residential real estate, corporate M&A deals, and corporate aspects of private client deals. His advice includes profits on trading, VAT, SDLT and capital taxes.

He advises on a range of corporate tax issues, covering taxes on UK residential and commercial property transactions, withholding taxes on international finance deals, tax provisions in corporate M&A transactions, structuring for UK and international clients, taxation of crypto-assets and taxes affecting employers and employees.

Elizabeth Small

  • 29 August 2024

Elizabeth is Head of Corporate Tax and a Partner in the Tax team. She specialises in corporate tax, with particular expertise in mergers and acquisitions, corporate reorganisations and restructurings. She advises institutional clients on forward-funding transactions and complex mixed-use developments, providing strategic advice on a wide range of tax issues, including VAT, SDLT and CIS.

She also advises on employee incentives and other tax-efficient ownership structures.

Elizabeth has particular expertise in enfranchisement matters. Her work includes advising the Phillimore Estate and The Crown Estate on enfranchisement claims and the management issues arising from their property portfolios.

Her experience spans both commercial and residential property, including hotels, bars, care homes, student accommodation, offices and prime residential assets. She advises a broad range of clients, including pension funds, international property developers and landed estates.

Known for her practical and commercial approach, Elizabeth helps clients navigate complex tax issues with clear and effective advice. She combines deep technical knowledge with extensive transactional experience to support clients in achieving their commercial objectives.

Heather Corben

  • 29 August 2024
Heather Corben

Acknowledging her invaluable ‘can‑do attitude’ and ‘creative thinking,’ Heather’s clients cite ‘her knowledge of complex multi‑jurisdiction corporate structures’ and her ‘extensive network when working with unusual jurisdictions.’

As a Partner in the Tax team, Heather has a wealth of knowledge in direct and indirect tax issues and regularly advises on corporation tax, capital gains tax (including NRCGT), income tax, national insurance contributions, VAT, stamp duty land tax and the Construction Industry Scheme. She advises a wide variety of clients on corporate real estate transactions, acquisitions, disposals, developments and joint ventures. Her experience includes advising on hotels, student accommodation, care homes, commercial and mixed‑use developments. Heather is also an expert in real estate fund structures.

She advises on M&A transactions, corporate reorganisations and setting up share incentive plans.

Heather’s priority is to provide clients with clear advice and support in challenging situations, always ensuring that she has a complete understanding of their commercial objectives and striving to meet these in an efficient manner.

Her clients include domestic and international property investors and developers, institutional real estate investors (including pension funds), blockchain and crypto‑asset businesses, corporates, international executives and high‑net‑worth individuals.

Heather’s wide‑ranging experience includes everything from advising on the tax aspects of the purchase of a football club to working with a small UK start‑up right through its lifecycle to becoming a major international group.