Market leading insight for tax experts
View online issue

Refinancing of a corporate group owning UK property

Peter Jackson (Taylor Wessing) answers a query on the refinancing of a corporate group owning UK property assets.

Question

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...

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:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
EDITOR'S PICKstar
Top