Real Estate Tax – 2026

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In person at Gray’s Inn, London

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Practical guidance on tax structuring for real estate including:

Development masterclass looking at developer and vendor tax issues

Taxation of overages

Choosing a structure: corporates and partnerships

Buying corporate vehicles which hold UK land

Private client aspects

Tax litigation update and current issues panel session

If you’d like to attend, please download the below form and email the completed version to info@prtconferences.com 

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0840 – 0900 Welcome

(Tea, coffee & pastries)

 

0900 – 0905 Chairman’s Introduction

 

0905 – 1030 Development Masterclass: Tax Issues for Developers and Vendors

• Securing capital treatment for landowners
• Saving and deferring SDLT for developers – what can be done?
• Application of transactions in land rules
• VAT input tax recovery for developers and  landowners
• Making sure that VAT options to tax are not disapplied
• Barter transactions: tax impact of swapping works for land.
• Tax treatment of joint ventures
• Land pooling prior to sale – what best to do?
• Residential property developer tax pitfalls; sales to housing associations
• Impact of the CIS and domestic reverse charging for VAT
• Collapsing trusts and SPVs and extracting the property

Michael Thomas KC and Richard Woolich, DLA Piper

 

1030 – 1050 Break

(Tea, coffee & biscuits)

 

1050 – 1135 Tax issues arising on overages and     deferred consideration

• Uncertain and contingent consideration for SDLT
• Deferral of SDLT – common pitfalls
• The VAT position at acquisition
• Sale of the land with an overage obligation in place: SDLT and VAT
• Implications of the variation of an overage right

Helen Coward, Simmons & Simmons

 

1135 – 1235 Structuring for UK and International Real Estate Transactions

• Basic structures: UK companies, partnerships, overseas companies and offshore unit trusts
• Establishing flexible structures for investment in multiple jurisdictions
• European Options: Sub-holding vehicle options
• Fund Pooling Vehicle considerations

Michael Gaughan, EY

 

1235 – 1330 Lunch

 

1330 – 1430 Buying and selling corporate vehicles which hold UK land

• Key tax benefits/implications of acquiring an SPV
• Tax protections for the buyer and W&I insurance issues
• Tax due diligence considerations/issues
• VAT and transaction fees
• Specific issues for JPUTs

Jacob Gilkes, CMS

 

1430 – 1510 Private client aspects

Private client tax considerations when investing in UK residential real estate – structuring issues including:

• Annual tax on enveloped dwellings
• Capital gains tax and corporation tax considerations
• Inheritance tax issues for individuals and trustees
• UK tax implications of occupation by beneficiaries of trust owned property
• Loans and collateral for loans
• Foreign structures e.g. LLCs and revocable trusts

Emma-Jane Weider and Rebecca Waterhouse, Maurice Turnor Gardner

(continues after tea break)

 

1510 – 1530 Tea

 

1550 – 1630 Contentious Real Estate Tax Update

• How to keep out of trouble when undertaking transactions
• Where are we on Section 75A FA 2003 after Tower One and Brindley Place?
• More recent cases
• Where are HMRC attacking?
• Managing HMRC enquiries

Michael Thomas KC, Pump Court Tax Chambers

 

1630 – 1700 Interactive panel session

• More tax opportunities, pitfalls and miscellaneous points of current interest
• Q&A

All speakers

 

1700 Conference Closes

The conference will be followed by informal drinks

Michael Thomas KC

Michael is a barrister at Pump Court Tax Chambers.  He advises and litigates on all areas of the UK tax code. For over two decades Michael has had a notable specialism in real estate tax.  During that time he has advised on countless development and investment projects. Michael acts for taxpayers in disputes against HMRC, both as advocate before the Tax Tribunal and Higher Courts and in providing strategic and tactical guidance to achieve early resolutions. He sits on the ICAEW VAT and Duties Committee and the CLA Tax Committee.

 

Richard Woolich

Richard is a tax partner at DLA Piper UK LLP. He is the co-author of Sweet & Maxwell’s Stamp Duty Land tax, recently publishing the 5^th Edition. In 2025 he was voted Indirect Tax lawyer of the year by International Tax Review, has been recommended individually in the Legal Directories for many years and is currently in the Hall of Fame for VAT and Indirect Tax. Richard has a broad practice in real estate tax, leading the UK VAT practice at DLA Piper and co-leading the International VAT practice.

 

Michael Gaughan

Michael is a Partner in EY’s Real Estate Tax team. Michael advises on real estate tax matters for UK and international transactions.  Michael advises some of the largest listed UK and international real estate companies, private equity funds and institutional investors.  Michael’s practice covers all areas of the real estate investment lifecycle including acquisition structuring (including platform and JV formation), diligence, ongoing advisory services, refinancings and sell-side assistance. Michael also has a specialism in advising UK REITs.

 

Helen Coward, Simmons & Simmons

Helen is a partner in the Tax team at Simmons & Simmons and a Chartered Tax Adviser. She provides both direct and indirect tax advice on a wide range of matters and transactions, with particular experience in residential development projects, joint venture structures and corporate real estate acquisitions and reorganisations.

 

Jacob Gilkes, CMS

Jacob is a partner in the CMS tax team.  He has a broad practice covering a wide range of direct and indirect tax issues.  He has extensive experience in relation to real estate transactions, including advising clients on tax efficient structures for property investment and development, joint ventures, acquisitions and disposals and the establishment and operation of REITs and other investment funds. His advice ranges from simple transactions through to complex structures optimising clients’ income/corporation tax, capital gains, stamp duty land tax and VAT positions.  Jacob also regularly advises on corporate transactions, where he has particular expertise in relation to demergers and restructurings.

 

Emma-Jane Weider, Maurice Turnor Gardner

Emma-Jane is the managing partner of private wealth law firm Maurice Turnor Gardner LLP. Her expertise spans the range of private wealth matters, with a particular interest in advising international clients on UK tax, estate planning and philanthropy matters.  She also has extensive experience of advising on trusts, foundations and other asset holding vehicles. Emma-Jane is a member of the Society of Trust and Estate Practitioners and an international fellow of the American College of Trust and Estate Counsel.

 

Rebecca Waterhouse, Maurice Turnor Gardner

Rebecca Waterhouse advises UK-based and international clients on a wide range of UK tax and estate planning, and the establishment and management of trusts and other asset-holding structures that operate across multiple jurisdictions. Her clients include individuals, trustees and family offices, based in the UK and abroad, and Rebecca regularly advises on the taxation of UK residential property held by and for the benefit of HNW and UHNW individuals.

If you’d like to attend, please download the below form and email the completed version to info@prtconferences.com