Real estate taxation
The Tax Group works closely with the Real Estate Group advising on structuring acquisitions and disposals of property including:
- considering the use of special purpose vehicles
- considering the use of limited partnership structures (where investors may be corporates, funds or individuals)
- identifying opportunities for making requisite claims for depreciation allowances in respect of fixtures through apportionment of purchase price to those items and identification of other property tax related issues (eg, withholding tax in the context of the sub-contractors in the UK Construction Industry Scheme)
- dealing with all value added tax issues arising out of property acquisitions, development and disposals including the Capital Goods Scheme, transfer of going concern issues and sector specific issues (eg, hotel and leisure)
- advising in relation to land transfer and registration taxes mitigation structures in relation to property acquisitions and developments (including, in the UK, forward purchase structures, group and acquisition reliefs, limited partnership structures, unit trust arrangements etc).