For many years heritage property has attracted various reliefs from taxation leading to a complex web of law and HMRC practice. These can make the ownership of works of art, historic houses and estates, which are often acquired through inheritance, complex and daunting.
Our team of art and heritage lawyers supports and guides our clients through the complexities of this area. We frequently advise clients on the tax efficient passing of collections or property down the generations; on appropriate ownership structures; the claiming of heritage reliefs and the negotiation of exemptions and undertakings with HMRC (and acceptance in lieu schemes).
We work regularly with the leading auction houses, valuers and other experts.
Areas of focus
Our expertise in art and heritage law includes the following:
- Structuring to enable collections to pass down the generations tax efficiently.
- Advice on the appropriate vehicles for the ownership of collections of works of art.
- Securing and maintaining tax reliefs for heritage property.
- Negotiating exemptions and undertakings with HMRC.
- Loan agreements with museums and art galleries.
- Agreeing private treaty sales, acceptance in lieu and hybrid schemes.
- Working with auction houses and dealers to achieve the best outcome on a sale, at the minimum burden of tax.
- Advice on disputes, usually related to attribution or valuation.
- Advice to non-UK domiciliaries on the use of offshore funds to acquire works of art.