Jersey 2025 and Beyond: A Premier Hub for UK Real Estate Structuring

For over two decades, Jersey has established itself as a premier financial centre for structuring investments into UK real estate. Its appeal lies in a combination of political and regulatory stability, a competitive product suite and a deep pool of experienced professionals.

Jersey’s prominence began in the early 2000s with the widespread use of Jersey Property Unit Trusts (JPUTs), particularly during the 2004–2005 rush to benefit from Stamp Duty Land Tax (SDLT) seeding relief. Even after the relief ended in 2006, JPUTs remained attractive due to their tax efficiency and flexibility.

In 2019, UK tax reforms brought offshore and onshore investors onto a more level playing field by introducing the taxation of gains on UK land disposals by non-residents. Despite this, Jersey’s reputation, infrastructure, and service quality ensured its continued relevance. Investors from pension funds to sovereign wealth funds continue to see the value in using Jersey structures.

STRUCTURING INVESTMENT INTO UK REAL ESTATE IN 2025 AND BEYOND

1. Private REITs

Once the domain of public listed real estate groups, private REITs have gained traction due to relaxed listing requirements and regime simplification. The rise in UK Corporation Tax to 25% has further increased their appeal and private REITs are currently a very popular structuring choice.

Jersey companies, with UK boards, are popular when structuring REITs. Benefits include:

·       Simpler distribution rules (solvency-based rather than profit-based)

·       No stamp duty on share transfers

·       No mandatory audits or public filings for private companies

2. Qualified Asset Holding Companies (QAHCs)

Introduced in 2022, the QAHC regime offers benefits for non-UK real estate and debt investments. Potentially a structuring choice alongside a REIT (holding UK assets) to hold overseas real estate, for an investor desiring a UK-centric platform. Like REITs, QAHCs must be UK tax resident but can be domiciled in Jersey, with the same aforementioned benefits being applicable.

3. JPUTs

JPUTs remain a staple for UK real estate investment, especially for single-asset deals and joint ventures. Their continued popularity is driven by:

·       Flexibility in trust instruments

·       Suitability for exempt investors (e.g., pension funds, charities)

·       Efficient exits via unit disposals which do not suffer stamp duty

JPUTs are not subject to regime rules like REITs and thus remain the primary choice for holding development property, such as BTR projects.

4. Funds

Cost efficiency is a major consideration for fund managers, especially now with more challenging market conditions. Jersey offers a compelling alternative to Luxembourg and the UK with:

•            Lower setup and operational costs

•            No mandatory AIFM or Depositary

•            Efficient EU marketing via National Private Placement Regimes

The Jersey Private Fund (JPF) is particularly popular, with over 700 launched since 2017. Jersey funds can also be combined with the REIT regime and the HMRC Exemption election where applicable. Recent enhancements in July 2025, make the JPF even more versatile.

The new UK Reserved Investor Fund (RIF), launched in March 2025, offers a new UK fund product. Like a Luxembourg Fund, the costs associated with mandatory AIFM and Depositary rules apply which is not the case for the flexible and proven JPUT.

MARKET TRENDS AND OUTLOOK

Geopolitical and economic uncertainties and events, not least the pandemic and inflation, have impacted investment volumes in recent years. Occupational performance of UK real estate has been resilient across sectors. There are clear signs of recovery with investors showing stronger interest in the UK real estate market.

Private REITs and JPUTs are well placed to continue being the most trusted structuring options.

WHY JERSEY STILL STANDS OUT

Jersey’s success is not just about tax or regulation, it is about people and infrastructure. The jurisdiction boasts:

•            High-quality legal, accounting, and administrative professionals

•            A strong brand reputation among onshore advisers

•            Operational efficiency and responsiveness

FINAL THOUGHTS

Jersey offers a comprehensive package with a wide range of structuring options, cost-effective and proportionate regulation and top-tier professional services. While global competition is intensifying, Jersey’s blend of quality, experience and innovation ensures it remains a leading choice for UK real estate investment structures.

To read the full article including views and discussion between the authors please click here.

Authors:  James Le Bailly, Partner, Real Estate Lead for KPMG in the Crown Dependencies, Simon Vardon, Independent Director and Tom Davies, London Office Head for Bedell Cristin