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UK Commercial Property - Understanding the Tax Issues

Investigate all tax aspects of UK commercial property from purchase through to sale

Majestic building with detailed windows and a dark sky a symbol of the city's rich heritage

A one-day course

This property tax course covers the following eight modules:

  • Definitions of UK Commercial Property
    • What counts as residential and what counts as commercial?
    • The tax consequences of designation of commercial versus residential property as well as the validity of capital allowances and interest relief.
  • Trading versus investment.
    • An analysis of the badges of trade which assists in differentiating between trading and investment activities.
    • The implications of trading versus investment are examined.
    • A detailed look at the income tax, capital gains tax and IHT consequences of the different designations.

We also look at HMRC’s attitude in the designations and the guidance and case law which underpins this.

  • Capital versus Revenue
    • An extensive review of the different treatments.
    • In particular a review of recent, relevant case law.
    • This looks at the impact of the accounting treatment as well as an analysis of the expenditure as well as the context of any capital projects.

In addition, we also take a look at the notional expenditure as well as the issues regarding dilapidated property and new tenancies.

  • Capital allowances
    • The basic rules and the impact of the hundred per cent expensing regime

This will particularly focus on the outcome of recent case law. This has extended the potential use of plant. In the context of potentially unlimited capital allowances, this has become a more critical issue. The impact of the fixture and fittings election is also examined in addition the practical aspects when the property is sold are also considered.

  • Interest considerations to include rules for deductibility of interest.
    • Property companies have been adversely affected both by the corporate interest restrictions and HMRC’s increased use of the unallowable purpose rule.

The property tax course at Redcliffe Training considers the practical issues in terms of interest deductions which have become particularly relevant given the rise in interest rates.

  • Corporate Interest Restrictions
    • Outline of the rules and effects on property companies.
  • Annual tax on enveloped dwellings – the potential traps.
    • Consider the annual filing requirements for ATED including how to claim exemptions.
  • Stamp Duty considerations.
    • Commercial Property is normally subject to lower rates of SDLT than residential property.
    • The course considers some of the challenges within the Stamp Duty Land Tax regime and in particular the anti-avoidance mechanisms that have been developed by HMRC.

Our trainer is the Director of a consultancy company specialising in taxation, share scheme advice, reward and lecturing. He has developed a specialised share scheme service for small companies and advises FTSE companies on communication.

The lecturing covers most aspects of Direct Taxation but his particular interests include employment taxation and transfer pricing, which poses unusual conceptual challenges.

Previous to this he worked for Henderson for nearly 9 years, leading the Share Schemes team for part of this time.

He took the level 7 CIPD Masters qualification whilst at Henderson. Before Henderson, he was with Australian Mutual Provident (AMP) and helped set up one of the first Share Incentive Plans (SIP) for large companies in 2001. It was so unusual at the time that the Revenue phoned the trainer to find out how they could encourage more large companies to adopt SIP.

Our trainer started his career in taxation and for the following 16 years worked in three of the “Big Four” accountancy firms. He ended up as a Senior Manager with Deloitte & Touche, having worked on issues such as profit-related pay, share schemes, expatriate tax, tax investigations, reward management, US taxation, transfer pricing and corporate tax.

Away from work, the trainer likes cricket, history, skiing, tennis and gardening. He gives lectures on history which helps keep his presentation skills fresh.

This property tax course is designed to fully equip participants with a broad understanding and extended knowledge of the taxation rules in respect of income from UK commercial property.

  • This property tax course concentrates on the tax challenges for UK commercial property.
  • Whilst UK residential property has been subject to significant changes in tax legislation which have generally raised the burden of tax on residential landlords, commercial property has not generally seen the same challenges.
  • This training course leader is an industry specialist with direct experience.
  • Course is detailed covering important required knowledge & information.

Our property tax training courses are designed to specifically examine the tax issues and opportunities arising from investing in commercial property.

Property tax training courses at Redcliffe aim to investigate all tax aspects of UK commercial property from purchase through to sale.

In addition, this course looks at the statuses of property companies, and their ability to claim capital allowances and interest relief. Delivered by an industry professional with an in-depth working knowledge of property tax, this course covers everything required.

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