Property Tax

Specialist tax advice for investors, developers and businesses for whom property is central to the case

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Property is one of the most tax-sensitive assets a business or investor can hold.

The same transaction, structured differently, can produce materially different SDLT, capital allowances and chargeable gains outcomes. The difference between the right structure and the wrong one is often measured in six or seven figures and by the time contracts are exchanged it is usually too late to change it.

Our property tax team advises on the structuring decisions that shape every property a client acquires, develops, holds or disposes of.

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How we deliver property tax advice

Macalvins advises on the structuring decisions that sit behind every property transaction, including:

  • Entity choice
  • Financing
  • VAT treatment
  • SDLT analysis
  • Capital allowances.

We work with you and your legal advisers before contracts are exchanged, so the tax position is settled before the deal is documented.

Where the property is being acquired into an existing group, we analyse the implications for that group’s wider tax position alongside the transaction itself.

On development work, we advise on the trading versus investment distinction, the VAT treatment of the development, the structuring of any joint venture or forward-funding arrangement and the eventual disposal mechanics.

On holding structures, we advise on ATED where it applies, the option to tax on commercial property, the capital goods scheme implications and the design of group structures for property businesses of scale.

Where you are investing internationally, we co-ordinate with the relevant local advisers through PrimeGlobal or directly.

Cross-border property structures are an area where local and UK tax analysis must align precisely and we manage that alignment as part of the engagement.

As a Top 100 UK accountancy firm with international reach through PrimeGlobal, we bring the technical depth and the international co-ordination that complex property structures need.

What you can expect
from our property tax team

Three principles shape how we work on property:

Engaged at structuring stage

Our most valuable work is done before the transaction is fixed. We are accustomed to being in the room with legal advisers and commercial principals as the structure is being shaped, not consulted afterwards.

Capital allowances treated seriously

Capital allowances analysis is integrated into acquisition advice, with section 198 elections, fixtures analyses and SBA positions handled with the technical care they require. Historic review work, where claims have been left under-optimised by previous advisers, is a regular part of our practice.

International alignment

Cross-border property structures are co-ordinated with the relevant local tax advisers, so the UK analysis and the local analysis sit together rather than in parallel.

Property clients work with us because they want their tax adviser positioned upstream of the transaction – a trusted guide who is in the room before the structure is fixed, with the technical authority and commercial judgment to shape it rather than simply report on what it will cost.

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Why choose Macalvins?

With our team, you get precision, continuity and the kind of considered advice that comes from people who know your numbers as well as you do.

As a Top 100 UK accountancy firm with international reach through PrimeGlobal, Macalvins brings that depth of expertise to every client, at every stage of growth.

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Frequently Asked Questions faq

We are negotiating an acquisition — when should we involve you?

Before heads of terms are committed to. SDLT analysis, VAT treatment, the option to tax position, capital allowances elections under section 198 and the structuring of the acquiring entity are all materially easier to optimise before the deal is documented than after.

Can you advise on UK property held by offshore structures?

Yes. UK property held by non-resident corporate vehicles sits within a regime that has evolved substantially in recent years — ATED, non-resident landlord rules, the 2019 non-resident CGT changes and the wider non-dom landscape changes from April 2025. We advise on the regime as it currently stands and on structural reviews where existing arrangements need to be reconsidered against it.

How does your work integrate with our legal team?

Directly and routinely. Tax and legal structuring on property transactions are tightly interdependent and we work alongside the legal team in real time during a transaction — reviewing draft contracts, agreeing CPSE responses on tax matters and confirming the SDLT and VAT positions before exchange.

Mr. Jackson
@mrjackson
Mr. Jackson
@mrjackson