The case of Brindleyplace Holdings S.à r.l (BP Holdings) v HMRC [2024] UKFTT 808 (TC) involved the acquisition of a market-standard (at the time) holding structure of properties in Birmingham (‘the Properties’) and the subsequent de-enveloping of the Properties into the ownership of Brindleyplace Holding S.à r.l (BP Holding). BP Holding was a Luxembourg holding vehicle of several German pension schemes.
The Properties were owned by an English limited partnership (the Partnership) of which the partners were (i) the trustee of a Jersey property unit trust (the JPUT) (ii) the Partnership’s general partner (the GP) and (iii) a Scottish limited partnership (the Carry LP).
The transaction consisted of the following steps (ignoring the minority 0.2% holding of units in the JPUT for simplicity):
Step 1: BP Holding acquired (i) the shares in the GP (ii) the Carry LP’s interest in the Partnership and (iii) 99.8% of the units...
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The case of Brindleyplace Holdings S.à r.l (BP Holdings) v HMRC [2024] UKFTT 808 (TC) involved the acquisition of a market-standard (at the time) holding structure of properties in Birmingham (‘the Properties’) and the subsequent de-enveloping of the Properties into the ownership of Brindleyplace Holding S.à r.l (BP Holding). BP Holding was a Luxembourg holding vehicle of several German pension schemes.
The Properties were owned by an English limited partnership (the Partnership) of which the partners were (i) the trustee of a Jersey property unit trust (the JPUT) (ii) the Partnership’s general partner (the GP) and (iii) a Scottish limited partnership (the Carry LP).
The transaction consisted of the following steps (ignoring the minority 0.2% holding of units in the JPUT for simplicity):
Step 1: BP Holding acquired (i) the shares in the GP (ii) the Carry LP’s interest in the Partnership and (iii) 99.8% of the units...
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:
