David Battiscombe
Personal & Family Wealth

When buying a home or other significant personal asset, it’s important to understand the tax implications and risks that might arise. We will help you find the best approach.

I am buying an asset

Below are some examples of the opportunities and challenges we respond to on behalf of wealth owners, their families and their other advisers.

I want to buy a jet which I will use for both personal and business purposes.

A tax-efficient way to own and use a private jet

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.

Debt-funded – and highly confidential – jet ownership

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.

I am buying a home in the UK.

Careful planning for a £40m property redevelopment

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.

A tax-efficient way to buy your children homes – and keep some control

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.

I am investing in UK real estate. What are the tax implications?

Careful answers to a £70m property question

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.

A limited company has advantages over personal ownership

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.

I want to invest tax efficiently.

Adjusting investments for tax efficiency

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

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