Trusts, SPVs, and REITs

Trusts, SPVs, and REITs: How High-Net-Worth Investors Structure Property Deals for Tax Advantages — And How Rise Capital Simplifies It

High-net-worth individuals (HNWIs) and family offices are increasingly turning to strategic investment vehicles like Trusts, Special Purpose Vehicles (SPVs), and Real Estate Investment Trusts (REITs) to optimise their exposure to property while minimising tax leakage, enhancing privacy, and protecting wealth.

But in a post-pandemic, high-interest-rate world — with rising scrutiny from HMRC and global tax regulators — structuring real estate investments correctly has never been more important.

At Rise Capital, we’ve built an investment model that gives HNWIs the tax-efficient benefits of SPVs, the asset protection of trusts, and the transparency of REIT-like reporting, all while avoiding the complexity and cost of managing multiple structures yourself.

Understanding the Structures: Trusts, SPVs, and REITs Explained

1. Trusts – Long-Term Wealth & Succession Planning

A trust is a legal structure that holds assets on behalf of beneficiaries. It’s often used by HNWIs to:

• Shield assets from inheritance tax (IHT)

• Manage multi-generational wealth

• Control the timing and method of distribution

• Achieve confidentiality and asset protection
  
  

Common types: Discretionary trusts, offshore trusts (e.g. Jersey, Isle of Man), life interest trusts.

Tax advantages:

• Defers IHT liabilities

• Can reduce CGT through lifetime planning

• Offers income splitting options across beneficiaries

2. SPVs – Project-Level Control and Tax Efficiency

A Special Purpose Vehicle (SPV) is a ring-fenced limited company, typically used to hold a single real estate project.

Why HNWIs use SPVs:

• Separates risk and liability from personal assets

• Enables efficient tax treatment via corporation tax

• Facilitates joint ventures or investor syndicates

• Enables clean exits via share sale vs asset sale
  
  

Tax benefits:

• Lower corporate tax rate (currently 25%) vs personal tax (up to 45%)

• Deductible costs and allowable expenses

• Streamlined profit extraction via dividends or loan repayments

3. REITs – Income Distribution & Liquidity (for Institutional-Scale Investment)

Real Estate Investment Trusts (REITs) are listed property companies that offer:

• Tax exemption on rental income and capital gains (if distributed)

• Regular dividend payments

• Liquidity through public markets
  

Limitations for HNWIs:

• Lower returns due to management costs

• Limited control over assets

• Subject to market volatility

• Unsuitable for direct project-level development investment

How HNWIs Combine These Structures

The Rise Capital Advantage: Structured for Simplicity, Designed for Flexibility

At Rise Capital, we integrate the benefits of SPV-based investing with trust- and tax-friendly mechanisms, giving HNWIs access to secure, fixed-return property development exposure without the administrative burden.

How Our Investment Model Works:

• Each project is held in a UK-based SPV, giving transparency, control, and ring-fenced security
  
  

• Investors can participate via:
  
  

  • Direct equity in the SPV
    
    

  • Loan notes (debt instruments)
    
    

  • Nominee structures via trusts or corporate vehicles
    
    

• 90% of project costs are raised through our debt-free syndicate, offering:
  
  

  • 10% fixed annual return
    
    

  • Capital held in escrow, not by the developer
    
    

• 10% equity comes from aligned equity investors — sharing in 40% of project profit
  
  

If the project doesn’t exit via sales within 3 months of completion, we activate our rental fallback strategy, generating:

• 4% rental yield to syndicate investors
  
  

• Ongoing rental income distributions
  
  

• Long-term equity upside participation
  
  

Why Our SPV-Based Model Works for Trusts, Family Offices & HNWIs

✔ Compatible with UK and offshore trust structures
✔ Shares or loan notes can be assigned to trusts or corporates
✔ Fixed, classified returns for clean tax treatment
✔ Escrow deployment aligns with fiduciary risk protocols
✔ No senior debt, no refinancing risk, no bank control
✔ Clean reporting for family offices and private wealth advisors

International Compatibility

Whether you are:

• A UK resident HNWI

• A non-dom investing through a discretionary trust

• A Middle Eastern family office using a BVI or DIFC structure

• A European investor seeking a clean SPV-based co-investment

…Rise Capital’s model gives you the tax-friendly, risk-managed access to UK property development you need — without the legacy complexity of bank-led schemes.

Let’s Build a Secure, Tax-Efficient Strategy — Together

We work directly with private clients, family offices, and tax advisors to ensure our model fits your structuring, reporting, and planning needs.