Nigel, Chris and Malcolm answered questions put to them during our live webinar on Mixed Partnerships and Hybrid Business Models which took place on 24th November 2021.

You can read the full list of questions asked and answered on the call, as well as find details on how to watch the replay.

  1. How can I avoid or reduce IHT?- properties are in personal names, not Companies
  2. How do you allocate more than 15% profit to the Ltd Co, without falling foul of transfer of income streams rules (not transferring underlying assets)?
  3. If tax is at a basic rate regardless of how much I draw, is this because I am running down my capital account?
  4. You say that the structure has to be mainly property, although my understanding is that to get business relief, it just needs to be trading, can it be non-property?
  5. You say the max tax is 20%, although we have the NI tax on top of this, am I right?
  6. I am an “accidental landlord” and need help not only on my 2 properties but also with my general PAYE/Share Options (US) based and EIS investments – are you able to cover these other TAX scenarios or are you mainly focussed on Landlords?
  7. Is a group company with alphabet shares a similar solution?
  8. I’m a small new start in the UK offering comprehensive property sourcing services for private clients in Hong Kong and Singapore looking at investing in London B2L property, I arrange/facilitate all the services you talk about but with several providers – can you work with non-UK residents?
  9. Do you have a minimum value of profit or portfolio you would work with?
  10. What if you’re a non-UK resident?
  11. Can the hybrid structure protect us from care home fees when we’re no longer compos mentis?
  12. Can form 17 be used among family members where ownership is in one name only?
  13. Once one engages with you does one have to use all your services?
  14. You have not mentioned CGT by transferring to an LLP if it is incorporated. Surely there is a tax implication by moving to such an LLP?
  15. What if your accounts have already been submitted to HMRC so payment is due in Jan? Can you still the structure?
  16. I’m intending on purchasing a Guesthouse BNB with 18 self-contained properties, do I purchase this in a limited company or in my personal name?
  17. Does HMRC see this as a tax avoidance scheme?
  18. Could you elaborate on how you would transfer the equity but still keep the property in your name?
  19. Can you put a property in a SIPP?
  20. Can different members of the family join, siblings, parents and children?
  21. Do you charge ongoing fees?
  22. Can you leave properties as gifts without IHT?
  23. What would your advice be to a foreign investor who is intending to invest in properties in the UK – would you buy in your name up until the net income hits the £50k threshold when you can no longer benefit from the 20% tax relief for interest? Then you start using a company to buy after that?
  24. How is dividend taxed when it’s paid to a non-resident? Is there a dividend withholding tax to pay?
  25. To split the income with my spouse on the property I own solely, how do I set up a Deed of Trust without paying Stamp Duty?
  26. I have been advised to use a Family Investment Company instead of an LLP to address Inheritance Tax. Comment?
  27. What are the CGT implications of including a property you once lived in before renting it out into the Hybrid structure?
  28. How does succession planning work with LLP?
  29. You mentioned Inheritance tax is paid more than £325k. Surely there is a property allowance of £175k and making £500k than this can be doubly for married couples i.e £1million?
  30. How does the structure prevent divorce and keep the money in my bloodline?
  31. What happens if you have personal losses for example of £100k. Would you delay moving to a partnership?
  32. Based on some of the questions asked by others, it seems that you are saying that there will be CGT on moving the equity into the LLP. I thought the benefit of LT4L is to this mitigated?
  33. If HMRC contacts us about the structure in several years time and challenges this. How will you support this? Have you had this issue in the past and how did you handle it?
  34. What if you own properties with siblings?
  35. Does an adopted child/ children have the same rights as a bloodline?
  36. Do you have to trade for three years in the Hybrid to benefit from this structure?
  37. If you work from home as most do now does that allow your residential property/ office to move into LLP?
  38. How long does it take to become a client?

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