Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

Costa del tax

13 June 2007
Issue: 4112 / Categories: Forum & Feedback

Our client bought a Spanish property some years ago. Due to the circumstances of the vendor, he in fact acquired the shares of a Gibraltar company, which in turn owned shares in a Spanish company which owned the property. The property has been occupied as a holiday home solely by our client. There has been no letting or income generated by the property, and all of the expenditure of maintaining it has been met directly by our client.

Our client bought a Spanish property some years ago. Due to the circumstances of the vendor he in fact acquired the shares of a Gibraltar company which in turn owned shares in a Spanish company which owned the property. The property has been occupied as a holiday home solely by our client. There has been no letting or income generated by the property and all of the expenditure of maintaining it has been met directly by our client.
Previously the question of beneficial occupation would have been an issue although the recent concession by HMRC indicates that they will not seek to tax the directors/members in the circumstances set out above.
However our client would like to unscramble the present ownership of the property in view of the hostile attitude of the Spanish authorities to corporate ownership with an offshore flavour and being mindful...

If you or your firm subscribes to Taxation.co.uk, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.

back to top icon