Below are some examples of the opportunities and challenges we respond to on behalf of wealth owners, their families and their other advisers.
Our client wanted to use a private jet for personal and business use.
We set up a charter company that would own the jet – and manage personal and third-party charter use – and made sure that using the jet in the UK would not trigger a UK tax charge.
Our client wanted to buy a private jet, but didn’t want to tie up too much of his capital. We arranged a beauty parade of lenders able to finance the jet and advised on the acquisition and finance.
Finally, we set up agreements for ongoing use and maintenance that included strict confidentiality clauses.
Our non-UK client decided to buy a £40m property. It was undergoing extensive redevelopment – including an underground car park, a swimming pool, and complex IT systems – but the work would not be finished when the deal was signed.
We made sure our client would not get caught in expensive construction wrangles. The contract stipulated a significant retention from the purchase price, that would only be paid out as works were completed, and included warranties for construction work. We advised on holding-structures that would mitigate tax and avoid succession issues.
Our clients lent their children money to buy their homes but took a charge over them. The debt gave them the control they wanted initially, but could be released over time as part of their long term inheritance-tax planning. They also retained title of the youngest child’s property as nominee.
Helping the children buy their own homes in this way also improved the long-term capital gains tax position.
We helped a wealthy Middle Eastern client structure a £70m portfolio of UK residential property.
The solution included personal ownership for properties which the family would use with a mix of debt and life insurance to minimise inheritance tax, and offshore structures for the rental properties. We keep a close eye on changes to residential property tax rules so we can keep the structure up to date.
Our UK client came to us with plans to grow a rented property portfolio. We showed her how a simple UK company structure would mean a lower tax bill allowing more of the profits to be re-invested. Money she lent to the company could also be repaid to her tax-free.
Transferring existing properties into the company would not have been tax-effective so most of the original portfolio properties remain in her name.
The piecemeal approach to taxation of UK residential property has led to an unhelpfully complex patchwork of overlapping tax charges.Damian Bloom, Partner - Head of Private Client
It’s important to get a property holding structure right from the outset, as moving properties later can trigger significant tax.Elizabeth Bradley, Partner - Head of Tax
Our client wanted to make an investment into a hotel management business. His target company included both trading and investment assets. We negotiated that the investment would be made but only after the group was reorganised to take out the investment assets.
Our client got the commercial exposure he wanted, with the tax advantages of holding trading assets.
“The piecemeal approach to taxation of UK residential property has led to an unhelpfully complex patchwork of overlapping tax charges.”Damian Bloom, Partner - Head of Private Client