UK property investment: transparent structures

A structure for collective investment in UK real estate which places each investor broadly in the same taxation position as if they had acquired their share of the underlying property directly can be characterised as ‘tax transparent’.

This approach to real estate tax planning is capable of accommodating many of the key tax drivers for a diverse range of categories of investors (see Box 1).

In appropriate cases tax transparent structures offer significant advantages in comparison to the use of overseas structures to acquire UK property:

• There is no necessity to conduct the central management and control of the business overseas to...