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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BVI and UK Beneficial Ownership Platform

The BVI Government has agreed to establish and maintain an electronic platform that will allow “the automatic right to unrestricted and timely” access for law enforcement agencies in the UK to accurate and current beneficial ownership information on corporate and legal entities incorporated in the BVI by the end of June 2017.