Returning corporate structures to the UK

KEY POINTS

• An offshore company holds UK property but is affected by proposed inheritance tax rules.
• Corporate structures may remain relevant for long-term investment growth.
• Consideration and the potential liabilities to stamp duty land tax.
• Transfers between group companies and qualifying conditions.
• The annual tax on enveloped dwellings and changing thresholds.

In the article ‘Welcome back’ (Taxation 8 June 2017) I suggested that offshore companies may no longer be ‘fit for purpose’ when holding UK residential property and that bringing the structure within the UK tax regime may now be beneficial.

We considered a scenario where after some transfers to take advantage of the excluded property rules the shares in Jersey Co are now owned by Mr X Mrs X their son granddaughter 1...