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JPUT |
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Prior to 22 March 2006, a significant number of UK property transactions (particularly commercial property sales) were structured as property transfers to newly established Jersey property unit trusts ("JPUTs") in such a way (by contribution of a property, or a portfolio of properties, to the JPUT in return for the issue to the contributor of units in the JPUT) that they qualified for "seeding" relief from SDLT (under section 64A of the UK's Finance Act 2003). Liquid Realty believes this transaction to be the second largest European real estate private equity secondary transaction in the past year after Liquid Realty's [pounds sterling]435 million (US$775 million) secondary JPUT transaction completed in the UK in 2006. Indeed, at some point it was considered that owning property through a JPUT provided a means of avoiding both the 2% entry charge and SDLT on the land acquisition. |
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