Tax transparent property funds

Tax transparent property funds (TTPFs) come in different forms. Two forms are very common: UK partnerships and non-UK unit trust schemes. Another form co-ownership authorised contractual schemes (ACSs) is relatively new but we estimate may already have acquired £7bn of UK real estate. There are other types of TTPFs such as non-UK partnerships exempt unit trust schemes formed in the UK and partnership-based or non-UK contractual schemes but these are rarer and are not considered further here. References below to partnerships are therefore to English limited partnership Scottish limited partnerships or UK limited liability partnerships. And references to unit trust schemes are to those formed under non-UK law usually in Jersey.

Partnerships offer great flexibility but they are most often used for...