Should UK commercial property be held by non-UK residents through a UK company or a non-UK resident company?

Recent changes to UK tax legislation have led to questions being raised as to whether non-UK residents should always choose to acquire commercial property in non-UK resident vehicles. It used to be the case that if you were a non-UK resident acquiring UK commercial property, it was generally better to structure the acquisition of such property so it was owned by a company in a non-UK, tax neutral jurisdiction. However, a number of recent developments have meant that this may no longer always be a sensible choice, particularly if there is a plan to develop land and sell it soon afterwards.

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