If a property is to be de-enveloped, the tax implications should be considered holistically and all the relevant taxes should be addressed. Marc Selby (Laytons) explains how the transaction should be structured.
Question: My clients a married couple who are UK resident and domiciled are proposing to purchase a BVI company (BVICo) whose sole asset is a freehold dwelling in London (‘the property’) valued at £6m. The purchase price for the BVICo shares will be £6m subject to adjustment so that the clients will acquire BVICo on a cash-free debt-free basis. The clients will fund the purchase price with their own cash. BVICo which is managed by its directors in Jersey purchased the property in 2010 for £2.5m with the aid of a mortgage of £2m which is still outstanding and which the seller will require to be discharged. BVICo has always used the...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
If a property is to be de-enveloped, the tax implications should be considered holistically and all the relevant taxes should be addressed. Marc Selby (Laytons) explains how the transaction should be structured.
Question: My clients a married couple who are UK resident and domiciled are proposing to purchase a BVI company (BVICo) whose sole asset is a freehold dwelling in London (‘the property’) valued at £6m. The purchase price for the BVICo shares will be £6m subject to adjustment so that the clients will acquire BVICo on a cash-free debt-free basis. The clients will fund the purchase price with their own cash. BVICo which is managed by its directors in Jersey purchased the property in 2010 for £2.5m with the aid of a mortgage of £2m which is still outstanding and which the seller will require to be discharged. BVICo has always used the...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
