In the Press
March 16, 2023

Spring Budget 2023: Tax Analysis (LexisNexis)

LexisNexis' tax analysis provides a summary of key tax announcements made in the Spring Budget. Tax partner Laura Charkin remarked — 'We have many clients setting up REITs beneath limited partnership fund structures currently, so the changes to the REIT rules and in particular the proposed relaxation of withholding tax on certain PIDs paid to a partnership are both timely and welcome. That said, the current proposal seems to only benefit investors entitled to gross payment and that technical category is actually quite limited; for example, it does not cover underlying tax-exempt investors, such as sovereigns or certain overseas pension schemes. It would be interesting to see whether this opens the door to considering if a more flexible system for allowing for differential withholding rates on PIDs paid to partnerships, by reference to underlying investors’ effective UK withholding tax rate and treaty status could be made to work.'