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Fifth money laundering directive and trust registration service

What: A consultation on expanding the scope of the Trust Registration Service pursuant to the Fifth Money Laundering Directive.

Our view: The rules need to be better targeted to the high-risk arrangements that the government is intending to capture.

The Future Homes Standard – changes to Part L and Part F of the Building Regulations for new dwellings

What: Consultation on the uplift to standards of Part L of the Building Regulations and changes to Part F. This uplift is the first step in achieving the Future Homes Standards.

Our view: The decarbonisation of the built environment must be driven by up-to-date building, design, and construction standards.

Budget representation

We submitted the BPF’s representation in advance of the forthcoming Budget. We highlight three areas where the property sector and Government can better work together to address the following challenges: levelling up investment in our towns and cities; decarbonising our built environment; and building more good homes. We also met with our contacts at HM Treasury’s Property Tax team this week to discuss these priorities and policy asks in more detail.

BPF Response: MHCLG’s technical consultation on Development corporation reform

We have submitted representations to the Ministry of Housing, Communities and Local Government (MHCLG) in response to their consultation on the effectiveness of legislation governing development corporations.

BPF Response: proposed amendments to the Heat Network (Metering and Billing) Regulations 2014.

We have submitted representations to the Department for Business, Energy & Industrial Strategy (BEIS) in response to their consultation on proposed amendments to the Heat Network (Metering and Billing) Regulations 2014. The amendments seek to ensure that, where technically feasible and cost-effective, final consumption metering devices are installed on heat and cooling networks and billing is based on consumption.

BPF Response: OECD ‘GloBE Pillar Two’ proposals

We responded to the OECD’s ‘GloBE Pillar Two’ consultation, which proposes to enable countries to tax profits where they have otherwise been taxed below a ‘minimum rate’. Our response highlights the need for a tailored approach for real estate investment structures, such as REITs, given their unique tax characteristics. We also stressed the importance of tax neutrality, allowing people to invest directly or collectively with similar tax outcomes

BPF response: Treasury Select Committee business rates

We responded to the Treasury Select Committee inquiry into business earlier this month.

BPF Response: NRCGT, property rich fund regulations

We submitted comments to HMRC on the draft NRCGT regulations relating to the treatment of property rich funds. We made a number of recommendation to ensure that there are no technical barriers to eligible investors making appropriate elections. In addition, we continue to stress the importance of functionality in the rules to allow funds to perform tax compliance and make payments of tax on behalf of their investors.

BPF Response: disclosure of cross border arrangements

We responded to HMRC's consultation on regulations that will require disclosure of certain cross-border arrangements that could be used to avoid or evade tax, as part of an EU directive known as DAC 6. Arrangements will be reportable from July 2020 and some transactions from June 2018 will be in scope. 

Tax treatment of asset holding companies in alternative fund structures

What: An HM Treasury consultation on the treatment of asset holding companies in alternative fund structures – part of the government’s ongoing work to explore how the UK could better support the alternative fund sector.

Our view: Investors in collective investment structures should achieve a similar tax outcome as if they had invested in the underlying real estate asset directly.

BPF Response: Partial exemption and capital goods scheme

We responded to HMRC’s call for evidence on simplification of partial exemption and the capital goods scheme highlighting areas for simplification and modernisation of the schemes. 

BPF Response: Consultation on Building a safer future

We submitted a response to the Building a Safer Future consultation. This follows up how the Government should implement the recommendations of the Hackitt Review. The results of the consultation should be forthcoming in the Autumn and a Bill in the next Queen’s Speech.