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Spring Budget 2024 - Will We See Material Reform?

Budgets are normally stories of two halves. The first half contains the headline-grabbing tax policy reforms that can be encapsulated in a snappy soundbite in the Budget speech, such as “Chancellor scraps the non-dom regime”....more

Impact of the UK’s Autumn Statement 2023 on Real Estate

In contrast to recent years, when there has been plenty for real estate tax lawyers to feast on, this Autumn Statement was fairly quiet.  Full expensing - After a prolonged period of time-limited, enhanced reliefs,...more

REIT reform in the UK - further modernisation

The Government has announced a further series of proposed changes to the UK REIT rules as part of the wider review of the UK funds regime and published draft legislation. This third set of changes are earmarked for...more

Spring Budget 2023 - tax impact on the real estate sector

Underneath the headline points, the Budget contained a number of measures designed to fulfil the Chancellor’s objective of encouraging growth and investment. There was broadly good news for those investing in UK real estate....more

Delay to Luxembourg-UK treaty changes until 2024 at the earliest

The changes to the Luxembourg-UK treaty will not be effective until 2024 at the earliest because Luxembourg did not ratify the treaty changes in 2022.  The delay was expected, as trailed in our earlier blog, where we explore...more

1/5/2023  /  Luxembourg , Tax Treaty , Treaties , UK

Delay to Luxembourg-UK treaty changes - impact on UK real estate

Unexpectedly, it is likely the changes to the Luxembourg-UK double tax treaty will not be effective until 2024 at the earliest. Where that is the case, some Luxembourg investors in UK property rich entities will have another...more

UK Mini-Budget in reverse - Tax impact on the real estate sector

In an attempt to calm the markets and ensure the UK’s economic stability the new Chancellor, Jeremy Hunt, gave a statement ahead of the scheduled Medium-Term Fiscal Plan on 31 October. He announced a reversal of almost...more

Mini-Budget September 2022 - Tax impact on the real estate sector

Summary - Some key measures for businesses in this sector were: ..Cancellation of the planned increase in the rate of corporation tax from 19% to 25% from April 2023. The rate will remain at 19%. ..From November...more

Sovereign investors likely to start paying UK tax - impact on UK real estate investment

The UK government is consulting on bringing overseas sovereign investors in UK real estate within the scope of UK direct tax from April 2024 as part of measures amending the scope of the sovereign immunity tax exemption. ...more

Tax changes to Luxembourg structures investing in UK real estate

The UK and Luxembourg have renegotiated their double tax treaty. The new treaty has been published, but is not yet in force. Significant changes have been made to the capital gains tax article amongst other provisions....more

New Residential Property Developer Tax: the design of the tax

In this blog we consider the current design of the residential property developer tax (RPDT). Separately we have blogged on the triggers for liability. This blog is based on the current draft of the legislation issued on 20...more

Promoting UK funds - Can the new qualifying asset holding company compete with Luxembourg?

This is likely to be a key reflection when considering the details issued in July about the new UK holding company regime for “qualifying asset holding companies” (QAHCs). The new regime is intended to make the UK more...more

UK economic statement: VAT cut for hospitality sector and SDLT saving for residential property

After the broad brush measures taken at the start of the COVID-19 crisis, UK Chancellor, Rishi Sunak, is now targeting help for some of the hardest hit sectors of the economy and is supporting jobs in particular. In his...more

Spring Budget 2020 – how does it impact on Real Estate?

In contrast to recent years it has been a quiet Budget for real estate tax. In particular, there was no big announcement of any further levelling of the playing field between resident and non-resident investors in UK land:...more

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