HOLDING UK PROPERTY WITHIN OFFSHORE STRUCTURES
Overview
The question of offshore structures holding UK situs property is one that directors and trustees in international finance centres contend with on an ongoing basis; it is one which should be reviewed regularly. This question may be focussed on queries from clients (usually non-UK) wanting to invest in UK property via offshore structures, or indeed, in respect of existing structures and whether the structure is still required.
The workshop will look at the holding of UK property during a timeline of pre-purchase, ownership, and disposal. It will look at the various taxes that apply generally, and how they apply at each stage of the ownership cycle. It will be interactive and utilise practical exercises to emphasise the areas covered. It will not make participants tax experts but will highlight what needs to be considered by them to avoid pitfalls and assumptions on treatment.
The course is delivered by Bernard O’Kelly BCL, AITI CTA, Barrister-at-Law, Fios Limited, Isle of Man. Bernard has been providing practical tax advice and solutions ‘offshore’ for 30 years.
Who should attend?
- Accountants
- Bankers
- CSPs
- Custodians
- Fiduciary specialists
- Tax specialists
- Trustees
Content Overview
The Ownership Cycle
- The Taxes that apply
- The definitions of those taxes to ensure clear application throughout the cycle
- Buying the Property and Considerations
- Is the structure right for the client?
- Existing client owned property
- Traditional Structure v Property Partnerships – an overview
- Existing client owned property and considerations
- Lifetime thresholds and the care required
- Supplementary charges
- Non-Primary residences
- Offshore companies
- Anti-Avoidance clearance and HMRC
Owning the Property
- The taxes relevant and their application
- Where & when
- What tax is becoming ‘historical?
- Restrictions on reliefs available during this part of the cycle
- Disposal of the Property – The taxes relevant and their application
- Where & when
- Tax that has a non-resident application
- Exit charges
The Common Pitfalls
Duration
1 half day
Price
£245 + VAT
A 10% discount will be applied to the 3rd or more attendees from the same firm. Companies may wish to consider the delivery of an in-house workshop.
