Introduction
Jersey Property Unit Trusts ('JPUTs')
have been used extensively as a vehicle to acquire and hold UK
property. Whilst previously the key driver for this was the seeding
relief exemption from UK Stamp Duty Land Tax
('SDLT'), which the Chancellor abolished
in his 2006 Budget, there are other key attractions of a JPUT. This
article summarises the key benefits of a JPUT, and outlines the
regulatory framework in Jersey for the establishment of a JPUT.
Key Benefits Of A JPUT
Fiscal Transparency
A prime attraction of a JPUT is that it can be structured as a
'Baker Trust', which is recognised as being transparent for
income tax so that for UK tax purposes income is treated as
directly attributable to the unit holders. Unit holders are able to
set off expenses of the JPUT against that income.
