Specialist Real Estate Tax

Freeths tax structured the investment by LDC into UniHomes, the market leading student accommodation advertising and payment platform.

The investment will support UniHomes expansion across the UK. Based in Sheffield and operating in over 50 locations nationwide, UniHomes connects students with thousands of student properties offering all-inclusive living. Letting agents are able to integrate the UniHomes platform with their back-office systems and generate enquiries.

Founded in 2015 by Phil Greaves, Bradley Cox and Luca Mori, UniHomes will use LDC’s investment to accelerate its regional growth ambitions and further develop the platform and service provision for both its student and letting agent customers.

Freeths tax advised on the demerger and wider reorganisation of the property-holding structure of a Danish and UK tax resident healthcare group.

Freeths transferred the UK care homes and operating companies from Danish entities to a common UK intermediary holding company. The transaction brought the UK care homes under an ‘umbrella’ of a UK holding company which streamlined the group structure by the removal of the Danish entities and enabled a more centralised, UK-based management of the UK care home side of the business.

Freeths structured the transaction, advised on the treatment and foreign entity classification for UK tax purposes of the relevant Danish entities involved in the reorganisation (including for SDLT group relief purposes), applied for HMRC’s confirmation on the entity classification and availability of tax relief and advised on the overall tax treatment including the ‘central management and control’ for corporate residency purposes and practical steps in relation to tax residency.

Freeths tax advised on the cross-border restructuring of a group of Luxembourg incorporated companies, which held significant real estate assets and development opportunities in Germany. The advice guided and enabled a Part 26A Companies Act 2006 debt restructuring plan.

The tax team’s role in this transaction was to advise on the numerous tax implications of the restructure to ensure that the restructuring completed with no adverse tax consequences. Freeths also advised on the appropriate steps to ensure that each of the relevant companies involved in the restructure was able to become or remain tax resident in its desired jurisdiction alongside UK VAT registration requirements. The advice was provided promptly in order to meet strict court deadlines.

The restructuring allowed for the potential rescue of a number of companies in Luxembourg which are involved in the construction of high-value properties in Germany from insolvency and involved the release and appropriation of a number of debts.

Freeths tax advised on the implementation of the HMO leasing business model of an international property management company.

Detailed written tax advice was prepared on the business model and the corporation tax, SDLT, VAT, CIS, and withholding tax implications of operating the business from the UK.

Europe’s largest living operating company is entering the UK HMO market, which has the potential to transform the co-living property market in the UK.

Freeths tax advised on tax issues relating to the client’s acquisition of leasehold land, to develop and operate residential assisted living accommodation.

The transaction allowed the client and its group to expand their business of providing assisted living accommodation to more areas across the UK.

The tax team’s role in this transaction was to provide detailed advice on the various property tax implications including VAT, SDLT, Construction Industry Scheme and Capital Allowances. Freeths tax team also negotiated the tax clauses in both the lease agreement and development agreement, while also reviewing the documents to ensure they did not impact the tax treatment of the transaction.

Freeths tax advised on the sale of a large portfolio of student accommodation and rental properties by a UK resident company whose sole shareholder is an Israeli national.

The advice has provided the company and shareholder with the option to dispose of the property portfolio of £18m in the most tax efficient way.

The tax team’s role in this transaction was to advise on the corporation tax implications of the disposal of the property by the company as well as the residency of the company following the disposal. Freeths also advised on the possible UK tax implications to an Israeli national of the different options of extraction of the funds from the company following the sale of the portfolio.