Instruction received to provide tax advice for a non-UK resident looking to purchase an elegant 6,000 sq ft six storey residential town house, with a mews property attached, situated just off the prestigious Sloane Square, Belgravia.

The client has a number of homes around the world and also has a considerable portfolio of commercial property. As a new client, we reviewed the existing holdings and the structures used to ensure that they were still fit for their purpose and met the aims and objectives of the client, in light of recent important changes. For the new property, a summary of the tax consequences stemming from the different ownership options for the property was prepared, focusing on Stamp Duty Land Tax (“SDLT”), Annual Tax on Enveloped Dwelling (“ATED”), Capital Gains Tax (“CGT”) and Inheritance Tax (“IHT”).

In the end a trust structure was established that would provide protection and flexibility for the client who had not fully decided on the property’s future purpose. The trust structure offered a lower charge to SDLT than ownership via a company and also meant the ATED charge did not apply.

The client required borrowing to fund the property purchase, so through our in-house Private Office an introduction was made to another business within the Knox group of companies to facilitate the best deal possible.

Please note that this case study reflects the facts, circumstances and tax position at the time the project was undertaken. It has not been updated for any subsequent change in tax law or practice and must not be construed as advice, or otherwise relied upon for any purpose.