Corporate property tax

Expert legal guidance on corporate property tax matters

From acquisition and development through to leasing, disposals and dispute resolution, our corporate property tax team delivers targeted, commercially focused advice to help clients stay compliant and navigate the evolving UK real estate tax landscape.

What is corporate property tax?

Corporate property tax encompasses a range of direct and indirect tax issues associated with acquiring, holding, and disposing of commercial real estate assets. This includes Stamp Duty Land Tax (SDLT), VAT, Capital Gains Tax, and other direct taxes relevant to UK land transactions.

Whether you’re an institutional investor acquiring a portfolio, a landlord negotiating lease terms, or a developer structuring a residential scheme, we provide nuanced advice to ensure tax efficiency and compliance across every stage.

How our corporate property tax team can help

For Investors, Landlords & Retail Clients

Stamp Duty Land Tax (SDLT):

• Technical structuring for reversionary leases, lease renewals, and variations
• Land swaps and exchanges
• Treatment of works carried out pre/post-completion
• Structuring transactions involving partnerships and joint ventures
• Sale and leaseback arrangements
• Overage provisions and tenant inducement analysis

VAT:

• Guidance on exercising the option to tax and managing disapplications:
  • Capital Goods Scheme
  • Development financier disapplication
  • Other exemptions and risk mitigation strategies
• Transfers of going concerns (TOGCs) including access to our bespoke toolkit:
  • Client-facing guidance
  • Red flag diagnostics
  • Document checklists and clause banks
• Structuring sale and leaseback transactions, lease variations, overage, and land barter arrangements

Direct Taxation:

• Transactions in UK land and implications for UK and non-UK entities
• Non-resident Capital Gains Tax (CGT) compliance
• Capital allowances advice, especially for embedded fixtures and acquisitions

Dispute-Linked Tax Matters:

• Lease surrenders, breaks, and associated SDLT/VAT implications
• Dilapidation settlements and the tax treatment of release of rights
• Specialist advice on rights of light and other easement releases

Property Acquisition Structuring:

• Direct acquisitions
• Through UK companies or offshore/UK unit trusts (JPUTs and GPUTs)
• VAT and capital allowances considerations in transaction documentation

For Developers & Development Fund Clients

Development Structuring:

• Drafting development agreements, including VAT mechanics and use of VAT accounts
• Navigating the Construction Industry Scheme (CIS) and residential property developer tax

SDLT:

• Managing timing of payments
• Land contributions and exchanges
• Works carried out pre-completion
• Overage clauses and timing implications

VAT:

• Zero-rating for qualifying residential developments, including golden brick
• VAT advice relating to ‘alternative’ property interests, including student accommodation, social housing and care homes
• Application of options to tax, capital goods scheme, and relevant charitable/residential usage
• VAT grouping and recovery optimisation

Land Pooling Arrangements:

• Direct tax advice relating to land pooling
• Indirect tax advice in relation to land transfers, including in respect of cross-options
• Advising on the tax implications of promotion agreements

Document Support:

• Drafting tax-robust commercial terms, especially around VAT and capital allowances
• Tailored precedent clauses and negotiation support for institutional frameworks

Who we work with

We support a wide range of clients, including:

• Property investment companies
• Commercial landlords and developers
• Corporate occupiers
• Institutional investors
• SMEs and startups with property holdings

Why choose our corporate property tax lawyers?

Our lawyers combine deep technical tax knowledge with real-world property insight. We work collaboratively across disciplines – legal, tax, and planning – to structure deals that are both compliant and commercially sound. Whether it’s unlocking SDLT reliefs or implementing tax-efficient JV arrangements, we partner with clients to deliver results.

Get in touch

If you’d like to speak to one of our corporate property tax specialists, please contact us today.