Today is: 30 July 2010
Sipp Purchases
Lakeman
Andrew personally owned a restaurant, nightclub, bars and a commercial shop, near Carcassonne France, which he had developed with local support and a restaurateur as his tenant. Andrew has a well-funded SIPP scheme and decided to sell the restaurant, shops and night-club owned through an SCI to his SIPP in order to release cash. The transaction involved insuring that the SIPP was well-secured with a rental income and completed successfully. Andrew transferred his SIPP to Freedom SIPP who working with London solicitors Sykes Anderson had the necessary expertise to deal with all the pension conveyancing and tax aspects of the transaction. Andrew said "The transaction took some time for David Anderson at Sykes Anderson to sort out but the transaction completed successfully and I am very pleased with both my decision and the professional support provided by Sykes Anderson and Freedom SIPP."
Website: http://www.labatisse.co.uk/
Mr R purchased a leaseback property in one of the leading French ski resorts for €400,000 using €300,000 from his SIPP and €100,000 by way of mortgage from one of the mainstream French banks.
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Mr L purchased a hotel for €800,000 with €600,000 from his SIPP and €200,000 borrowings and arranged for an hotel operating company to run the hotel for him. Mr L plans to retire early at 55 in 4 year’s time and will then take over from the operating company and run the hotel himself as part of his early retirement arrangements. The €200,000 mortgage will be paid off by then. The income from operating the hotel will fund his retirement with the hotel remaining a pension asset to be sold when he is no longer able to continue with the business.
Mrs W owned a leaseback property worth €350.000 with a €50,000 mortgage. She sold the leaseback property to her SIPP for €300,000 net. The transaction was structured with no French stamp duty paid and there was no clawback of French VAT. The result was that Mrs W had the €300,000 cash to reinvest and the SIPP owned the leaseback property.
Other Matters
French company sale
We dealt with the sale of a non-French UK company which owns substantial French real estate during the first quarter of 2008. The sale price ran into tens of millions of euros and involved major law firms in several jurisdictions as well as one of the top four accountancy practices. The entire transaction was coordinated by Sykes Anderson LLP and completed successfully. Sykes Anderson acted as a coordinator for both the commercial and tax advice.
Re-location to Monaco
During the first part of 2008 we have been active advising UK residents on re-location to Monaco and structuring existing French property investments with a view to current UK residents becoming Monegasque resident. We have also been involved in detailed analysis of French income tax rules relating to international business people.
Non-UK domiciled individual
We have advised a very high net worth UK resident, who is not UK domiciled, on his position following the budget changes. We have been involved in analysing his tax position with other lawyers with a view to him relocating to Monaco.
Monegasque residents investing in France
We have worked with leading tax counsel in England and France regarding structuring a vehicle to enable residents of Monaco to invest into French real estate, optimising their tax position. We have also used a similar structure for a high net worth individual resident outside the EU in a non-tax treaty country with France to optimise her tax position on an investment in French real estate. We have coordinated the tax advice in France and the UK as well as dealt with the drafting of all documentation for the structure in the UK.
Private jets
We have continued to be active in the first quarter of 2008, in the purchase of private jets. Our focus has been on tax-effective structures to enable purchasers to avoid benefit in kind charges, and also to make use of the capital allowances on the purchase of the jet elsewhere in their UK trading businesses. Our work has been carried out in conjunction with leading UK tax counsel and tax advisers in several other jurisdictions in which the purchasers are resident.