Real Estate & Property Holding Structures

Holding real estate through international structures can enhance asset protection, simplify multi-jurisdictional ownership, and improve tax efficiency on

Real Estate & Property Holding Structures covers comparative legal assessment, documentation and coordination across international jurisdictions. It is typically relevant to businesses, investors and families considering a cross-border structure or activity. There is no single offshore regime: legal effects, disclosures, taxation and permissions depend on the selected jurisdiction, relevant residence rules and the facts of each case.

Key points

  • There is no single international or offshore legal regime.
  • Rules are verified for every jurisdiction considered.
  • Beneficial ownership, tax residence and reporting are assessed separately.
  • No tax result, confidentiality, licence or timeline is guaranteed.

Jurisdiction and applicable framework

The law and competent-authority requirements of the selected jurisdiction apply, together with rules in relevant tax-residence and operating jurisdictions. Comparison precedes selection and implementation.

Holding real estate through international structures can enhance asset protection, simplify multi-jurisdictional ownership, and improve tax efficiency on rental income and capital gains. We advise on the design of property-holding structures using SPVs, trusts, and foundations in international jurisdictions, ensuring compliance with substance requirements and tax-reporting obligations.

We select the holding vehicle and jurisdiction based on the location of the underlying property, the investor's tax residence, and the applicable double-taxation treaties. The structure must satisfy both the property-law requirements of the country where the asset sits and the substance rules of the holding jurisdiction.

What this includes

  • Property-holding structure design
  • SPV formation & governance
  • Tax-treaty & withholding-tax analysis
  • Substance-requirement compliance
  • Ongoing administration & reporting

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