property developer

Property developer growth sparks restructure

property developer

Case Study29th Jul 2021

Contributors

Related services

Our Client 

Our client commenced in business as a property developer. Over a number of years, a significant element of the profit achieved from property development was invested in property which was being let to third parties. 

The investment property was purchased in group companies and was now significant enough to prevent tax reliefs available to trading groups from being available. 

AAB were approached to advise on how to tax efficiently separate the trading and non-trading activities. 

Our Approach 

  • Identification of the tax reliefs which were unavailable to the group’s shareholders, and the group, as a result of the significance of the non-trading activities 
  • Review of tax legislation to identify alternatives for tax efficiently separating the trading and non-trading activities in the group 
  • Presentation of alternatives and their associated tax effect to the shareholders of the group, resulting in a restructure exercise 
  • Leading the implementation of the restructure exercise to achieve the segregation of the trading activities in a fresh corporate structure from the other activities 

The Outcome 

  • An implemented restructure delivered a separate trading group which could be sold for significantly reduced tax liability and achievement of the separation of the trading activities from other activities allowing both to operate efficiently independent of one another 
  • Our experience in delivering tax efficient restructure exercises allowed the business owners to focus on running the business knowing that the historic tax risks were being taken care of through the restructure 
  • The group were able to access valuable tax reliefs on the shares owned in the separated trading corporate structure 
  • Subsequent to the restructure we worked on with the property developer client to diligence the trading structure ready for sale and we are now assisting in marketing the business for disposal. On disposal the shareholders’ ultimate objective will have been achieved with an associated tax liability of 10%; 50% lower than that which would have been suffered without restructure. 

Sign up for the latest industry insights

  1. Blog29th Oct 2025

    Derek Gemmell, Head of Innovations Tax and author of blog about budget announcement

    There are no crystal balls for a Budget announcement

    As we approach the Budget Announcement being made by Rachel Reeves on 26 November, social media is alive with suggestions about what will be announced and what will be changing as the government attempts to reduce the c.£20bn hole in…

    By Derek Gemmell

    View more
  2. Blog26th Mar 2024

    Derek Gemmell, Head of Innovations Tax and author of blog about budget announcement

    R&D Tax Relief Procedures: HMRC’s Latest Notification Requirement

    In today’s fast-paced business landscape, where staying ahead often means innovating and adapting to change, research and development (R&D) tax credits have emerged as a key tool for businesses, especially for small and medium-sized enterprises (SMEs).  As an R&D tax…

    By Derek Gemmell

    View more
  3. Blog15th Feb 2022

    Innovation in the Textile Sector

    Research and Development in the Textile Sector.

    By Derek Gemmell

    View more
  4. Blog27th Aug 2020

    Potential Changes to Qualifying Costs for Research and Development Tax Relief

    Following on from the Spring Budget 2020, the Government has announced that they are now consulting on the eligible expenditure that can be included in Research and Development (“R&D”) tax credit claims. The last formal consultation on the qualifying cost…

    By Derek Gemmell

    View more