Peter Jackson (Taylor Wessing) answers a query on the refinancing of a corporate group owning UK property assets.
A Luxembourg resident company (LuxCo) owns a number of subsidiaries incorporated and tax resident in Jersey (the ‘Jersey SPVs’). Each Jersey SPV owns rented UK commercial property held as an investment. LuxCo also owns a subsidiary incorporated and tax resident in the UK (‘UK Sub’) holding rented UK commercial property as an investment. The corporate group is currently financed by way of a five year loan made to LuxCo by a third party UK resident company. LuxCo has lent on monies under unsecured intra-group loans to each of its subsidiaries. The intra-group loans are governed by Luxembourg law and enforceable in Luxembourg. Interest payable by UK Sub to LuxCo under the intra-group loan is paid gross following a claim for relief from UK withholding tax (UK WHT) under...
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Peter Jackson (Taylor Wessing) answers a query on the refinancing of a corporate group owning UK property assets.
A Luxembourg resident company (LuxCo) owns a number of subsidiaries incorporated and tax resident in Jersey (the ‘Jersey SPVs’). Each Jersey SPV owns rented UK commercial property held as an investment. LuxCo also owns a subsidiary incorporated and tax resident in the UK (‘UK Sub’) holding rented UK commercial property as an investment. The corporate group is currently financed by way of a five year loan made to LuxCo by a third party UK resident company. LuxCo has lent on monies under unsecured intra-group loans to each of its subsidiaries. The intra-group loans are governed by Luxembourg law and enforceable in Luxembourg. Interest payable by UK Sub to LuxCo under the intra-group loan is paid gross following a claim for relief from UK withholding tax (UK WHT) under...
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