European Tax Bulletin For Real Estate Funds.

Extract


European Tax Bulletin For Real Estate Funds.

UK: Effective tax rate - pan-European real estate funds

A common theme for maturing pan-European estate funds is a steady increase in the effective tax rate as the fund matures due to, for example, the utilisation of brought forward tax losses, utilisation of capital allowances/write down in the tax depreciation basis of underlying assets.

As such, a recent area of focus for many funds is consideration of methods of minimising local country taxes payable whilst also achieving certain commercial objectives (e.g. rationalisation of entities, improved flexibility to repatriate cash and creation of accounting efficiencies).

As a consequence of recent legislative and practice changes there are a number of op...

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