Real Estate
Real Estate Acquisition & Diversification
Hold global property that fits your tax and wealth strategy.
Overview
Acquiring international real estate in personal name — without an appropriate holding structure and without consideration of the acquisition, holding and disposal tax profile — creates unnecessary inheritance exposure, capital gains liability on disposal, complications for mortgage financing, and probate complexity across multiple jurisdictions on death. The real cost of incorrect structuring is typically not visible at acquisition but crystallises at disposal or death, when it is too late to restructure without triggering additional tax charges. HPT Group advises on how to acquire, hold and dispose of international real estate in the most tax-efficient, creditor-protected and succession-friendly manner. Every engagement begins with an analysis of the specific property jurisdiction's tax regime — stamp duty, annual property tax, income tax on rental proceeds, capital gains on disposal and inheritance tax — and then maps the optimal holding structure against your personal tax residency, your succession objectives, your financing requirements and your portfolio strategy. The holding structure must work in the property jurisdiction, in your residency jurisdiction, and in the succession jurisdiction simultaneously. Our clients include HNWI individuals acquiring residential real estate in Dubai, Lisbon, Cyprus, Malta or Monaco as a primary or secondary residence, investors building income-producing commercial or residential property portfolios in multiple jurisdictions, and entrepreneurs and family offices using real estate investment as part of a citizenship by investment or residency by investment programme. We work alongside local property lawyers, surveyors and mortgage advisors in each jurisdiction — we provide the structural and tax overlay that they typically do not.
What's Included
- Offshore property holding structures
- Real estate IBC formations
- Cross-border financing advisory
- CBI real estate pathways
- Tax-efficient disposal planning
Typical Engagement Timeline
From first contact to
fully implemented structure.
Timelines vary by engagement complexity and jurisdiction. The steps below reflect a typical instruction from initial application through to active implementation.
Day 1
Application
Submit your application and structured intake form. We review your situation, confirm fit, and agree scope and fees in writing before any work begins.
Days 3–5
Diagnosis Call
A 90-minute senior strategy call to cover your current structure, residency, revenue flows, risk exposure and goals. All relevant documents reviewed in advance.
Days 10–21
Blueprint Delivery
Written memorandum delivered covering current position analysis, proposed structure with diagrams, jurisdiction rationale, and implementation sequencing.
Weeks 3–18
Implementation
Entity formation, banking introductions, registered agent setup, compliance calendar and substance design — all coordinated and managed by the HPT senior team.
Day 1
Application
Submit your application and structured intake form. We review your situation, confirm fit, and agree scope and fees in writing before any work begins.
Days 3–5
Diagnosis Call
A 90-minute senior strategy call to cover your current structure, residency, revenue flows, risk exposure and goals. All relevant documents reviewed in advance.
Days 10–21
Blueprint Delivery
Written memorandum delivered covering current position analysis, proposed structure with diagrams, jurisdiction rationale, and implementation sequencing.
Weeks 3–18
Implementation
Entity formation, banking introductions, registered agent setup, compliance calendar and substance design — all coordinated and managed by the HPT senior team.
Capabilities
What this service covers.
Offshore Property Holding Structures
We design IBC, LLC and foundation holding structures for international real estate that insulate the asset from the owner's personal estate for succession purposes, provide a clean share-transfer mechanism on death without multi-jurisdictional probate, and — where applicable — facilitate group financing, tax-efficient rental income extraction, and portfolio aggregation across multiple properties. A BVI IBC holding a Dubai apartment and a Cyprus villa can transfer both assets by a single share transfer document, avoiding both Dubai and Cyprus probate proceedings. The holding structure must be assessed against each property jurisdiction's specific anti-avoidance rules targeting offshore corporate property ownership.
Mortgage & Finance Structuring
Property held in offshore holding entities can be financed by private lenders, Swiss cantonal banks, Liechtenstein private banks, UAE banks and specialist non-bank lenders. We advise on how the entity structure affects available financing — many domestic mortgage lenders will not lend to offshore companies, requiring either a personal guarantee or a restructuring to a local entity. For portfolio financing, we advise on cross-collateralisation arrangements, inter-company loan structures, and the tax deductibility of interest costs in the property-holding jurisdiction. We introduce to appropriate private lenders where conventional mortgage financing is unavailable for the structure.
CBI Real Estate Pathways
Several jurisdictions combine qualifying real estate investment with citizenship or residency by investment: Grenada (USD 220,000 in approved developments), St Kitts & Nevis (USD 200,000 in approved real estate), Antigua (USD 200,000), Portugal (EUR 500,000+ in qualifying areas, now restricted to commercial and renovation properties following 2023 Golden Visa amendments), Greece (EUR 250,000–800,000 depending on location), Malta (EUR 220,000 purchase or EUR 8,750 rental under GRP). We advise on the specific properties that qualify, the mandatory holding periods, whether the investment is competitive on a commercial basis after the CBI or residency period, and how the real estate purchase integrates with the citizenship application.
Tax-Efficient Disposal Planning
Capital gains on international property disposals are frequently taxable in the property jurisdiction under domestic law, regardless of where the vendor is tax resident — because most property-jurisdiction tax laws and double tax treaties (OECD Model Article 6 and Article 13(1)) reserve taxing rights on immovable property to the jurisdiction of situs. The key variables are: whether the property is held personally or through a company; whether the company shares are taxed as shares or as property (anti-avoidance rules in France, Spain and the UK treat shares in property-rich companies as direct property); the availability of any capital gains exemptions in the property jurisdiction; and the interaction with the vendor's personal residency capital gains regime.
Jurisdictions Covered
8+ jurisdictions.
Directly advised and operationally active.
Jurisdictions Covered
Where we operate and advise.
UAE (Dubai)
No capital gains tax on property disposals. No inheritance tax. No annual property tax (only a one-time 4% Dubai Land Department transfer fee on purchase). 100% foreign ownership in designated freehold areas (Palm Jumeirah, Downtown, Dubai Marina, DIFC). Rental yields 4–8% in residential, higher in commercial. Strong resale market and USD-pegged AED currency. UAE Golden Visa from AED 2,000,000 property value. Corporate holding via UAE Free Zone entity (DMCC or ADGM) available and tax-neutral.
Portugal
IMT (Imposto Municipal sobre Transmissões Onerosas de Imóveis) on purchase: 0–8% depending on value and property type. IMI (Imposto Municipal sobre Imóveis) annual property tax: 0.3–0.45% of tax value. Capital gains taxable in Portugal at 28% (residents: progressive rates with 50% exclusion for primary residence held over two years). NHR/IFICI regime exempts most foreign-source income but Portuguese-source rental income is taxable. Golden Visa (D2/investor visa) now restricted to commercial real estate, renovation properties and interior regions following 2023 amendments under Lei n.º 56/2023.
Cyprus
No inheritance tax in Cyprus. No annual wealth or property tax (abolished 2017). Transfer fees on purchase: 3–8% (currently 50% discount available for first registrations). Capital gains tax at 20% on Cyprus-situated immovable property only (movable property exempt). Rental income taxed at standard personal income tax rates with a 20% allowance for expenses. Cyprus International Trusts can hold Cypriot property with succession planning and some creditor protection benefits. Permanent Residency available from EUR 300,000 qualifying investment.
Malta
5% stamp duty on purchase (reduced rates for certain categories including first-time buyers and qualifying areas). No capital gains tax for Maltese residents on primary residence. Capital gains on investment property taxed at a final withholding of 8% on transfer value (or 5% in some circumstances) — a relatively low effective rate. Annual property tax (ground rent) is minimal. Maltese company holding structure available and commonly used for investment portfolios. Malta Global Residence Programme available for qualifying property purchase (EUR 220,000+).
Monaco
No capital gains tax on property in Monaco. No inheritance tax for direct family members (Monaco Law No. 1.121). No annual property tax. Purchase costs: 4.5–6.5% registration fees plus notarial fees. Property prices among the highest globally (EUR 50,000–100,000+ per sqm in prime areas). Monaco residency requires ownership or rental of Monaco property. SCI (Société Civile Immobilière) commonly used for Monaco property portfolio ownership to facilitate succession and co-ownership. French tax treaty applies to French nationals only.
Singapore
Additional Buyer's Stamp Duty (ABSD) applies to foreign buyers at 60% of purchase price (as of April 2023) — making direct Singaporean residential real estate acquisition prohibitively expensive for non-residents and non-citizens. Commercial real estate: ABSD does not apply. Property held through Singapore companies or funds may access different ABSD treatment in qualifying structures. Capital gains tax: none. Annual property tax based on annual value at progressive rates. Strong rental yields in commercial and industrial sectors.
Greece
Golden Visa from EUR 250,000 (€800,000 in Athens, Thessaloniki and major island zones from 2023 amendments under Law 5006/2022) qualifying real estate purchase. No inheritance tax for direct descendants. Transfer tax on purchase: 3.09% (standard). Capital gains tax: 15% on gains from real estate disposals (temporarily suspended for individual sellers since 2014 — confirm current status at time of acquisition). Rental income taxed at 15–45% progressive rates. EU residency with Schengen access.
United Kingdom
The most complex property tax regime for international investors. SDLT (Stamp Duty Land Tax) at 2–12% for residential plus 3% surcharge for additional dwellings plus 2% for non-UK residents — up to 17% in aggregate for high-value residential. Annual Tax on Enveloped Dwellings (ATED) applies to residential property worth over GBP 500,000 held in a company (from GBP 4,150 to GBP 269,450 per annum). Non-Resident Capital Gains Tax (NRCGT) applies to all UK property disposals by non-residents since April 2019. Offshore company holding structures for UK residential property are largely tax-neutralised by the 2013–2019 ATED and NRCGT legislative changes.
How It Works
From instruction to implementation.
Acquisition Structure Design
Before any purchase offer is made, we design the holding entity — IBC, LLC, foundation or personal name — based on the property jurisdiction's specific tax regime, your tax residency, your succession objectives, your financing requirements and any CBI or residency programme eligibility. We produce a written structural analysis covering acquisition costs (stamp duty, transfer fees, legal costs) under each holding option, annual holding costs, rental income tax treatment, capital gains tax on disposal, and estate/inheritance tax exposure — for both the structure and the personal fallback of direct ownership.
Entity Formation
We form the holding company or structure — BVI IBC, Cayman exempted company, Singapore private limited company, or UAE Free Zone entity — with the appropriate shareholding, director arrangements and banking coordination. We ensure the holding entity has an appropriate bank account for the purchase funds to flow through, and we prepare the UBO structure documentation required by the local conveyancer or notary. Where a UAE or Singapore entity is used, we coordinate with the local registry for property ownership registration in the entity's name.
Tax & Legal Coordination
We coordinate with local lawyers, notaries and tax advisors in the property jurisdiction to ensure the holding structure is correctly documented for local property law, properly registered with the relevant land registry, and correctly reported for local tax purposes. We draft or review the inter-company loan agreement if the holding company is funded by a shareholder loan (which affects interest deductibility and thin capitalisation), and we confirm the applicable double tax treaty position between the property jurisdiction and your residency jurisdiction for rental income and capital gains.
Ongoing Portfolio Management
Annual returns and compliance filings for all holding entities, rental income structuring and lease documentation review, property tax filings in the property jurisdiction, periodic revaluation of the holding structure as property values and portfolio composition change, and disposal planning — including engagement with the conveyancer and tax advisor in the property jurisdiction — when any property is to be sold. We also advise on portfolio financing reviews and the restructuring of existing direct property holdings into appropriate holding structures.
Comparable Client Outcomes
What clients have achieved with this service.
Anonymised and generalised for confidentiality. All outcomes reflect real engagements. Results vary by individual circumstances, jurisdiction and timing.
- UK investor, Dubai portfolio
Four UAE properties restructured from personal to corporate ownership — annual rental income tax exposure reduced by 34% and succession position simplified across jurisdictions.
- European family office
Offshore holding structure for a €6.2M Spanish property investment designed — inheritance and wealth tax exposure reduced through compliant non-resident ownership structure.
- South African buyer, Mauritius villa
CBI real estate pathway and property holding company established concurrently — residency permit and clean title in a corporate vehicle achieved within a single 90-day engagement.
Key Questions
What clients ask us.
Straight answers to the questions that come up in every engagement. If your question is not here, ask us directly.
Ask a Question →Not always. For a single residential property in a jurisdiction with no inheritance tax, simple transfer taxes and straightforward capital gains treatment (UAE, Cyprus, Malta), personal ownership may be equally tax-efficient and simpler to administer. The case for a holding company becomes compelling when: the property jurisdiction has estate duty or inheritance tax on directly-owned property; multiple properties are involved (portfolio succession is dramatically simpler through a company); the owner is UK-domiciled (UK inheritance tax applies to worldwide assets for UK-domiciled individuals, including offshore property); or the property is income-producing and corporate tax treatment is more favourable than personal income tax.
In some jurisdictions and for specific lender types, yes. UAE banks (Emirates NBD, Mashreq) will lend to UAE Free Zone companies. Private banks in Switzerland and Liechtenstein will lend against property held in BVI or Cayman companies for HNWI clients with a private banking relationship. Specialist non-bank lenders in Guernsey and Jersey provide portfolio finance against offshore-held property. UK high street lenders have almost entirely ceased lending to offshore company structures following ATED and NRCGT legislation. We advise on which lenders will work with your specific holding structure and at what terms before any financing approach is made.
Property held directly in your personal name in most jurisdictions is subject to local succession law and potentially multiple concurrent probate proceedings — one in each jurisdiction where you own property. Property held in an offshore holding company passes by transferring the shares — a single transaction governed by the law of the company's incorporation jurisdiction, avoiding multi-jurisdictional probate entirely. The shares in the holding company are governed by your will or trust in your jurisdiction of domicile. This succession simplification is one of the most compelling arguments for corporate holding structures in an international property portfolio.
Yes — and they are jurisdiction-specific and evolving. UK: ATED applies to residential property worth over GBP 500,000 held in a company, with annual charges up to GBP 269,450; NRCGT applies to gains on all UK property disposed of by non-residents. France: Taxe de 3% sur la valeur vénale des immeubles applies to companies holding French property, with exemptions for listed entities and qualifying declarations. Spain: anti-avoidance rules treat transfers of shares in property-rich companies as direct property transfers for IRNR purposes. Each jurisdiction's rules must be assessed specifically before any structure is recommended.
ATED (Annual Tax on Enveloped Dwellings) under the Finance Act 2013 imposes an annual charge on residential property in the UK worth over GBP 500,000 that is held by a 'non-natural person' (company, partnership with corporate members, or collective investment scheme). Annual ATED charges range from GBP 4,150 (properties GBP 500,000–1,000,000) to GBP 269,450 (properties over GBP 20,000,000) for the 2025/26 tax year. Reliefs are available for property development, property rental businesses and farmhouses. Given the ATED charge, NRCGT on disposal and 3% SDLT surcharge, offshore company structures for UK residential property are rarely beneficial post-2019. We advise specifically on legacy structures and whether decorporation is advisable.
The most tax-efficient method of extracting rental income from a holding company depends on your personal residency and the jurisdictions involved. Options include: dividend distribution from the holding company to you personally (subject to withholding tax in the holding company jurisdiction and personal income tax in your residency jurisdiction); director's salary or management fee charged by you to the company (deductible at company level, taxable at personal level); inter-company loan repayment (not income, but requires the loan to have been made in the first place); or accumulation within the company and distribution on a later disposal of the company shares as capital gains rather than income. We advise on the most appropriate extraction strategy for your specific jurisdictional combination.
Important Notes
- —Local property law governs the property itself — the holding structure governs ownership, succession and tax treatment of the ownership interest, not the property's physical rights and obligations.
- —Anti-avoidance legislation targeting offshore property-holding structures has expanded significantly in the UK, France and Spain since 2013. Any existing structures should be reviewed against current law, and new structures must be assessed against current anti-avoidance rules before acquisition.
- —The interaction between the property jurisdiction's capital gains tax, the vendor's personal residency CGT regime, and the applicable double tax treaty must be analysed before disposal — not during conveyancing.
- —Transfer pricing rules apply to inter-company loans funding property purchases. The interest rate on any inter-company loan must be at arm's length and documented in a written agreement.
- —For CBI real estate routes, the qualifying property list and minimum investment amounts change frequently. We confirm current qualifying criteria before any purchase commitment is made.
- —Advisory fees from £2,500 for property structuring depending on complexity, number of properties, jurisdictions involved and extent of financing advisory required.
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