Every corporate or property transaction will involve some type of tax implication - and the primary concern of our Tax team is to ensure that our clients optimise their allowances, mitigate their liabilities and ensure that their corporate and property tax affairs are in order.
Advising on tax issues in relation to property investment, development, finance and funds work, we specialise in providing clear and strategic advice concerning direct and indirect taxes, including Stamp Duty Land Tax, VAT and business rates. Our clients include institutional and private investors, developers, entrepreneurs; both in the UK and international. We work tandem with our colleagues in the Real Estate and Private Client teams from an early stage.
When considering real estate strategy - the acquisition or disposal of assets, leasing, developing, constructing or investing in commercial property - numerous, and often competing, tax issues will arise and consideration needs to be given to:
- VAT on the purchase and development of the site
- SDLT on the purchase of the site
- direct taxation i.e. the taxation of any income, profits or gains that arise during your ownership of the site
- capital allowances which may serve to reduce your taxable income
- structuring the ownership of property to attract investors and to achieve a tax efficient exit
- bespoke property structures such as REITs and PAIFs
- the correct structuring of corporate transactions to ensure that the tax analysis aligns with the client's commercial objectives.
Our tax experts can advise across the board.
Schoolwork, Cash in the Attic and Tax Liabilities – How Working From Home Could Result in Unintended Tax Liabilities
Many of us are privileged and are able to work from home (WFH) during the current crisis. As a result, a large proportion of us are now well aware that WFH has many implications and we've all read articles about the importance of routine, a good breakfast, etc. However, there are also a number of fiscal consequences and your tax return may look a little different next time as a result of this prolonged period of WFH (and that will be subject to another blog!).
COVID-19: HMRC guidance on Company Residence, Permanent Establishment and related issues regarding the Economic Substance Test
Her Majesty's Revenue and Customs (HMRC) published guidance on 9 April on the implications of COVID-19-related travel restrictions on a company's residence status. Such travel restrictions may force directors or employees to be present in the UK when they would not be here under normal circumstances. This situation raises concerns as to whether a foreign company may become resident for tax purposes in the UK because the central management and control (CMC) of the company might be considered to have moved here.
The Government has recently announced a "VAT Holiday" for businesses, meaning that the VAT payment due for the periods ended 31 March 2020, 30 April 2020, 31 May 2020 and 30 June 2020 won't now be due until 31 March 2021.
Few would have anticipated only a few weeks ago that by March, a large part of the world, including the UK, would be or have been in virtual lockdown with many planes grounded and borders closed. However, that is the result of the spread of COVID-19 and, while there are clearly many more significant challenges in relation to this virus for health and the global economy, there are also a number of tax and immigration consequences for individuals with connections in more than one jurisdiction, as well as for those based in the UK.