How we restructured a St John's Wood property holding for £24,000 saving
Client X held a St John's Wood apartment worth around £2.1 million inside a company structure set up years earlier. The structure was incurring annual ATED charges and Corporation Tax with no remaining commercial justification, and the original privacy rationale had fallen away with beneficial ownership registers.
We modelled de-enveloping the property into personal ownership versus keeping the structure. We worked through the ATED position, the CGT on the company's disposal to the shareholder, the SDLT on transfer, and the ongoing savings from eliminating annual ATED, Corporation Tax and company running costs. We timed the de-enveloping to minimise the immediate tax cost and structured it correctly.