I’ve loved every minute of my first MIPIM, although I feel a little like I've run a marathon up and down La Croisette. Main topic of conversation for me was the UK CGT changes for non-residents and the impact on structures.
We’ve responded to the consultation asking for the government to
1. Align timings of CGT change and the move to corporation tax - and later rather than earlier to allow time for change
2. Keep legislation simple and give clarity on key issues for investors, such as detail on the land-rich companies test and exemptions for institutional investor
3. Reduce the administrative burden wherever possible
What will new structures look like? Many are looking at UK resident structures, perhaps retaining Jersey, Guernsey and Isle of Man vehicles and taking advantage of more flexible corporate law and established fiduciary centres.
REITs, perhaps listed on the re-branded TISE and the much anticipated IPSX once launched, are also expected to be in high demand.
The Government has introduced a flurry of wide-ranging tax reforms in recent years, increasing complexity and uncertainty for non-resident investors in UK real estate. Most recently, in the Autumn Budget 2017, the Chancellor launched a consultation on bringing gains on commercial property by offshore investors within the UK tax net.