UK tax planning with Special Purpose Vehicles ('SPV's)

There are a number of reasons why UK residents may use a Special Purpose Vehicle (SPV). Often an SPV is a UK or offshore company although not necessarily. An offshore foundation or specific type of company such as a protected cell company could be used.

Some of the the main occasions when an SPV could be used include:

• To hide ownership (eg by using an offshore company/foundation to hold particular assets)

• To isolate assets from financial risk

• To crystallise capital gains

• To separate assets for tax purposes

• To allow shares rather than underlying assets to be transferred.

In this guide we’ll look at some of these in detail.