Sovereign Immunity from Direct Taxation

We have expressed concern about the potential impact on investment as a result of changing the tax treatment of sovereign immune investors. Furthermore, these changes will result in significant complexity for existing investment structures where sovereigns are treated as “qualifying” (good) investors (including the REIT regime and Qualifying Asset Holding Company regime). The Government must act with care to ensure that existing investment structures and co-investors are not inadvertently penalised by these changes.