Commercial property transactions can involve a number of different taxes.  The purchase of the property is likely to result in a charge to Stamp Duty Land Tax (SDLT) and may also be subject to Value Added Tax (VAT). The sale of the property may generate a liability to Corporation Tax or Capital Gains Tax (CGT) as well as having other VAT implications.

Some of the tax implications, particularly SDLT and VAT, can vary significantly depending on the type of property – multi-occupancy properties such as care homes, for example, have different rules from single residences –  and the way the ownership is structured, for example personally, via a company or through a trust.

Specialist advice ensures the transaction is structured efficiently and reliefs are maximised.

Overseas individuals and high-net-worth (HNW)/ultra-high-net-worth (UHNW) families often hold UK property through offshore companies, trusts, or multi-jurisdiction holding structures. Rules on ATED (Annual Tax on Enveloped Dwellings), Capital Gains Tax (CGT) for non-residents, and Stamp Duty Land Tax (SDLT) surcharges mean the choice of structure has major tax consequences. Non-UK residents must plan for ATED and SDLT surcharges and CGT on disposals.

The owner’s intentions for the property – will the property be used by the owner personally, let to third parties, or developed – can also affect the most appropriate choice of ownership structure.

Our tailored advice helps balance tax efficiency, compliance, and confidentiality while aligning with and protecting long-term estate and succession plans.

Professional investors and family offices often benefit from corporate ownership due to lower Corporation Tax rates, flexibility in extracting profits, and succession planning advantages. However, it can also bring extra compliance and reporting as well as Stamp Duty Land Tax (SDLT) charges. At Arnold Hill, we model scenarios so you can make an informed choice aligned with your investment strategy and scale, financing, family objectives, and exit strategy including forward tax planning.

Early tax planning is critical for property developers as they need specialist advice at every stage: from land acquisition and financing, to VAT on construction, and Capital Gains Tax (CGT) or Corporation Tax on exit. Structuring the development through special purpose vehicles, joint ventures, or group companies can reduce risk and improve tax efficiency. Our UK property tax accountants work with developers from site purchase through to disposal to ensure available relief is captured and the tax profile supports the commercial outcome.

There are a range of reliefs that can make a significant difference to a property owner. VAT may be recoverable on cost for commercial projects, the cost of the building may be deductible from rental income arising from the property under the Capital Allowances regime and corporate owners can deduct in full their annual financing costs up to £2million per annum. The Government has designated certain areas as “Freeports” or “Investment Zones”. Qualifying property acquisitions in these areas will be exempt from SDLT on purchase.

The availability of reliefs depends on ownership, use, and timing. The key is knowing which apply to your circumstances and advanced planning. We review transactions to ensure you qualify, plan ahead to secure reliefs, and highlight opportunities often overlooked, particularly in commercial and development projects, so you don’t miss out on valuable tax-saving opportunities.

Property transactions often come with strict and short reporting deadlines. For example, SDLT must be reported and paid within 14 days of the purchase of a property and CGT must be reported within 60 days of sale. Owners may have additional disclosure requirements such as ATED returns and surcharges on residential property, while developers and companies face complex VAT and corporation tax reporting. At Arnold Hill, our property tax accountants manage these obligations on your behalf to avoid penalties and maintain full HMRC compliance.

Timing is critical with UK property tax and ideally a specialist tax accountant should be brought on during the transaction stage before contracts are signed. Early structuring advice ensures your client, whether they are a developer, family office or overseas investor, secures available reliefs and avoids costly mistakes.