Portfolio restructuring · 100 properties
Restructuring a 100-property family portfolio
How we are restructuring a family's 100 properties, held in personal names and several companies, to improve inheritance tax, succession and day-to-day management.
At a glance
- Client: a family with a 100-property portfolio spread across personal names and several limited companies
- How it was held: 25 properties personally by the parents, 15 personally by the father in joint ventures with business partners, and 60 across four or five limited companies with various family members
- The problem: no cohesive structure, which created difficulty for inheritance tax, succession and administration
- Approach: consolidation and incorporation into a group, inheritance tax planning (discretionary trusts, Family Investment Companies, freezer shares) and succession planning
- Status: a long-term restructure that is still in progress, so no final figures are given
The client
A family with a portfolio of 100 properties spread across various personal names and multiple limited companies. It was a classic case of success outgrowing the structure.
The challenge
The family had built a significant legacy, but the lack of a cohesive structure created difficulties for inheritance tax, succession planning and administrative management.
- 25 properties were held personally by the parents.
- 15 properties were held personally by the father in joint ventures with business partners.
- 60 properties were held across four or five different limited companies with various family members.
The properties were scattered across different legal entities, making them hard to manage effectively or tax-efficiently. With a portfolio of this size, the inheritance tax bill can be devastating if left unmanaged.
What we are doing
We do not start with tax products. We start with objectives. You must define what you want to achieve for your family and your business before you change a single deed.
- Consolidation and incorporation. Incorporating the personally held properties into a limited company structure. The aim is a group structure in which assets can be transferred between entities free from capital gains tax and stamp duty land tax.
- Inheritance tax mitigation. Exploring a combination of discretionary trusts to ring-fence assets, Family Investment Companies to centralise control and allow efficient wealth transfer, and freezer shares so that future growth on specific properties sits outside the parents' estate.
- Succession planning. Mapping out who the properties are intended for, including the children and grandchildren involved in the current company structures. The goal is to move the economic value to the next generation while maintaining control and minimising tax leakage at the point of transfer.
The outcome so far
This is a long-term restructure, not a one-off transaction, and the work is still in progress, so we are not quoting final tax figures. What is already clear is the shape of the result: one coherent structure in place of properties scattered across personal names, joint ventures and several companies, with inheritance tax and succession planned together.
What it shows
Success can outgrow a structure. Trading businesses and property assets need to be aligned so that the structure serves the family's objectives rather than creating unnecessary tax burdens. If you have outgrown your current structure, do not wait for a crisis to address it. Our specialist Family Investment Company practice explains how a Family Investment Company compares with a trust (opens in a new tab).
Figures describe one family's circumstances. Every case depends on its own facts and on the law at the time, and nothing here is a guarantee of a tax outcome.
