For HNW Real Estate Investors
From SPV to succession. Property structures planned for lenders, tax and the next generation.
Cross-border SPVs for prime residential and commercial real estate. SDLT, ATED, inheritance tax and NRCGT exposure reviewed with UK counsel. Lender requirements checked before formation.
Our view
The structure that holds a property outlasts the purchase.
Most acquisition advice ends at completion. We start there. The SPV that holds your London flat, the company that owns the Dubai tower, the trust that consolidates the family's European portfolio: those decisions compound across SDLT, ATED, NRCGT, mortgage, IHT and ultimately succession. We design the holding architecture before the conveyancer is briefed.
What we solve for property investors
Four decisions we work through with you.
- 01
Where does the SPV live?
Jersey, Guernsey, BVI, Luxembourg, UAE, Cyprus, Malta. Each carries different SDLT, ATED, NRCGT and IHT consequences for UK and EU property. We model each before formation.
- 02
Will the lender accept the structure?
Mortgage approval is the second hurdle after acquisition. We coordinate with the lender's structuring counsel and test the structure against the lender's stated criteria. The credit decision remains the lender's.
- 03
How does the structure survive the next generation?
Trust, foundation or family-office wrapper. The holding architecture is designed around the family's succession plan, not around this year's tax bill.
- 04
What happens at exit?
CGT, NRCGT, ATED, treaty position, and where the proceeds go next. Modelled at acquisition so the exit is not a surprise.
Services
The services these clients use most
Each can be engaged on its own, or combined with others as one matter.
- Real estate structuringReal estate held through vehicles that lenders, registries and tax authorities accept.Typically 4 to 8+ weeksTypically 4 to 8+ weeks
- Trusts and foundationsDiscretionary, fixed-interest, purpose, and reserved-power trusts. Panama and Nevis foundations.Typically 3 to 8+ weeksTypically 3 to 8+ weeks
- Company formationOnshore and offshore companies in the BVI, Cayman, the UAE, Singapore, the UK, Delaware and other jurisdictions, with substance documented and banking considered before formation.Typically 2 to 6+ weeksTypically 2 to 6+ weeks
- International bankingIntroductions to 45+ private and corporate banks across the UK, EU, GCC, Asia-Pacific, the Caribbean and the US.Typically 3 to 10+ weeksTypically 3 to 10+ weeks
- Fiduciary and compliance coordinationIndependent directors, AML programme design, economic substance and middle-office coordination for offshore structures, delivered through licensed counterparties.Live within 2 weeksLive within 2 weeks
- Tax residency planningTax residency planning with the statutory criteria documented, for moves to the UAE, Monaco, the Cayman Islands and elsewhere.Typically 4 to 12+ weeksTypically 4 to 12+ weeks
Where we work
Jurisdictions these clients use most often
We work with formation agents, banks and local counsel in each. We can look at others too.
Questions
Common questions
I'm acquiring prime UK property as a non-resident. SPV or personal name?
Can you place the mortgage too?
What about ATED reliefs?
Who we work with
Other clients we advise
Founders
Family offices
Fintech and payments
Professional advisers
Crypto and Web3
iGaming
Yachts and aircraftNot listed here?Tell us about your matterWe do not give legal or tax advice in jurisdictions where we are not qualified to do so; where needed, we coordinate local counsel and tax advisers.
Fees agreed in writing before work begins. Where a bank or provider pays us for an introduction, we tell you before the introduction is made.
See also what we will not do and prohibited and restricted matters.
Next step
Tell us about your matter.
A short application tells us what you need. We aim to reply within 48 hours. The first step is a diagnosis of where you stand today.