Creating a real estate holding company can make it possible to structure a property portfolio, separate different investments, facilitate the entry of partners, or organize the ownership of real estate assets in several countries.

But what is the best jurisdiction for a real estate holding company?

There is no universal answer. The optimal jurisdiction depends in particular on the location of the properties, the type of real estate held, financing, the shareholders’ tax residence, the taxation applicable to rental income and capital gains, and the availability of bank financing.

For international investors, several jurisdictions may be considered: Singapore, Hong Kong, the United Arab Emirates, and the United Kingdom.

The objective is not necessarily to choose the country with the lowest tax rate, but rather the one that offers the best balance between taxation, legal protection, financing, reputation, and international flexibility.

Why Create a Real Estate Holding Company?

A real estate holding company structure can be used to centralize or organize the ownership of multiple investments.

Depending on the project, a structure may, for example, take the following form:

Shareholder → Holding Company → Real Estate Companies → Real Estate Assets

For certain international projects, it may be preferable for each property or group of properties to be held by a separate company.

This structure can make it possible to:

• separate different assets;
• facilitate the entry of new investors;
• organize the transfer of wealth;
• distinguish between several real estate projects;
• centralize certain administrative functions;
• structure investments across several jurisdictions.

However, the tax and legal consequences should be carefully assessed before transferring an existing property to a company.

What Is the Best Jurisdiction for a Real Estate Holding Company?

Jurisdictions do not all offer the same advantages.

Jurisdiction	Real Estate Profile	Main Advantage	Key Consideration
🇦🇪 United Arab Emirates	International and regional real estate	International environment	Tax regime and substance requirements must be analyzed
🇸🇬 Singapore	Asian investments	Stability and credibility	Significant property taxes in certain circumstances
🇭🇰 Hong Kong	Real estate and Asian investments	Territorial taxation	Specific real estate and tax rules
🇬🇧 United Kingdom	UK and international real estate	Well-established legal framework	Detailed real estate taxation

The choice depends primarily on where the assets are located.

A company incorporated in a low-tax country generally cannot eliminate taxes due in the country where the property is located.

United Arab Emirates: An International Jurisdiction for Real Estate Investment

The United Arab Emirates have become an important jurisdiction for international investors, particularly in Dubai and Abu Dhabi.

The Corporate Tax regime applies, among other things, to businesses engaged in real estate management, construction, development, agency, and brokerage activities. The regime also contains specific rules for businesses established in Free Zones.

For a real estate holding company, it is therefore essential to distinguish between:

• simple investment holding;
• property rental;
• real estate development;
• buying and reselling;
• property management activities.

These activities may receive different tax treatment.

The UAE can be particularly attractive when an investor wishes to develop a regional or international portfolio from a jurisdiction with a well-developed financial and commercial ecosystem.

Suitable profile:

• international investors;
• entrepreneurs residing in the UAE;
• investors in Dubai real estate;
• families wishing to structure international assets;
• investors developing several projects in the region.

Singapore: A Strong Structure for Asian Real Estate

Singapore may be relevant for investors whose real estate portfolio is focused on Asia.

The jurisdiction offers strong institutional stability and an excellent reputation among international banks and investors.

However, particular attention must be paid to property stamp duties.

Singapore has, in particular, a specific Additional Conveyance Duties (ACD) regime concerning certain transactions involving interests in Property-Holding Entities that primarily hold residential properties in Singapore. The rules can result in significant duties on certain acquisitions or disposals.

This means that a Singapore holding company should not be selected solely on the basis of its corporate income tax rate.

The tax cost of acquiring, holding, and disposing of the assets must be analyzed.

Suitable profile:

• Asian real estate investors;
• international families;
• institutional investors;
• entrepreneurs seeking a highly credible structure;
• diversified portfolios in Asia.

Hong Kong: An Interesting Option for Investments in Asia

Hong Kong should also be considered for an international real estate holding company, particularly when investments are connected to Asia.

The Profits Tax regime is based on a territorial principle. For companies, the rate is 8.25% on the first HK$2 million of assessable profits under the two-tiered regime, and 16.5% thereafter.

However, real estate taxation must be analyzed separately.

When a company rents out real estate in Hong Kong, rental income may fall within the Profits Tax regime. The Inland Revenue Department also states that corporate property owners may be subject to Property Tax, with mechanisms available to prevent double taxation of the same income.

Hong Kong can therefore be particularly attractive for an investor seeking an Asian platform combining ownership, financing, and international development.

United Kingdom: A Jurisdiction Suited to UK Real Estate

The United Kingdom remains an important jurisdiction for international real estate investors.

A UK company can hold real estate and receive rental income. For a company, income derived from renting out a property is treated as property business income and may be subject to Corporation Tax.

The main rate of Corporation Tax is currently 25% where profits exceed £250,000, while the small profits rate is 19% on profits up to £50,000, with a Marginal Relief mechanism applying between the two thresholds.

The United Kingdom nevertheless offers a major advantage: its legal and financial environment is well known to international investors.

It can therefore be particularly suitable when properties are located in the UK or when investors wish to use a UK structure that is readily recognized by banks and commercial partners.

Offshore Real Estate Company: Is It Really Advantageous?

The expression “offshore real estate company” can be misleading.

When a foreign company owns real estate, the country in which the property is located generally retains taxation rights over income or certain real estate transactions.

For example, a non-resident company that owns property in the UK cannot simply assume that the property income is outside the scope of UK taxation. HMRC has a specific regime for non-resident companies receiving rental income from UK properties.

The real question is therefore:

Why use a foreign holding company rather than a local company?

An international structure can make sense when it serves a genuine purpose:

• a portfolio located in several countries;
• investors from several jurisdictions;
• organization of a real estate group;
• international financing;
• family wealth transfer or governance;
• separation between different projects.

By contrast, creating an offshore company solely to attempt to avoid local real estate taxes can result in a costly structure that is difficult to justify.

International Real Estate Holding Company: A Multi-Level Structure

For an international portfolio, a more sophisticated structure may be considered.

For example:

Investors / Family

↓

International Holding Company

↓

Real Estate SPV A — France

Real Estate SPV B — Spain

Real Estate SPV C — United Kingdom

The purpose of such an organization is, in particular, to separate risks and investments.

Each SPV can hold a specific asset or portfolio, while the holding company performs certain governance and ownership functions.

However, this architecture also creates additional costs: accounting, tax filings, bank accounts, directors, substance requirements, and regulatory obligations.

A more complex structure is therefore only relevant when it addresses a genuine economic or wealth-planning need.

How to Choose the Best Jurisdiction

Before creating a real estate holding company, it is recommended to analyze at least six criteria.

1. Location of the Properties

This is generally the first factor. Real estate taxation depends heavily on the country in which the property is located.

2. Nature of the Investment

A residential property intended for rental, a hotel, a commercial building, or a real estate development project may be subject to different tax treatments.

3. Taxation of Income

It is necessary to analyze taxation of rental income, capital gains, withholding taxes, and any applicable stamp duties.

4. Bank Financing

A real estate holding company must be able to obtain financing and manage the financial flows associated with acquisitions.

5. Tax Residence of the Shareholders

The personal taxation of the owners can have a significant impact on dividends, distributions, inheritances, or share disposals.

6. Tax Treaty and Substance

For an international structure, tax treaties, the company’s tax residence, and the reality of its management must be examined before making any decision.

Which Jurisdiction Should You Choose for Your Project?

Are You Mainly Investing in Dubai or the UAE?

A UAE structure may be particularly appropriate.

Is Your Portfolio Focused on Asia?

Singapore or Hong Kong may be worth comparing.

Do You Mainly Own Properties in the UK?

A UK structure may provide an appropriate legal and financial framework.

Do You Own Several Properties in Different Countries?

An international holding company with local SPVs may be more appropriate than a single foreign company directly holding all the assets.

Why Get Professional Assistance When Setting Up a Real Estate Holding Company?

An international real estate holding company should be designed around the assets it will actually hold.

The choice of jurisdiction should therefore be made after analyzing the portfolio, rather than before.

ICD Fiduciaries assists entrepreneurs and international investors with company formation, the establishment of international structures, and the search for professional banking solutions.

For a real estate project, the objective is to build a structure that is consistent with the countries where the properties, investors, and financial flows are located.

FAQ – International Real Estate Holding Company

What is the best jurisdiction for a real estate holding company?

There is no universally best jurisdiction. The UAE, Singapore, Hong Kong, and the UK may all be relevant depending on the location of the assets and the investor’s profile.

Can an offshore company own real estate?

Yes. A foreign company may, in certain circumstances, own real estate abroad. However, the country where the property is located may continue to tax income, gains, or transactions related to that asset.

Why create an international real estate holding company?

It can be used to organize multiple investments, separate risks, accommodate multiple investors, or structure a portfolio located in different countries.

Is it better to create a separate company for each property?

Not necessarily. A company for each asset can facilitate risk segregation, but it also increases administrative and accounting costs. The choice depends on the portfolio and financing arrangements.

What is the best structure for an international real estate portfolio?

A commonly considered structure is a holding company at the top level, with local companies (SPVs) holding the assets in each country. However, it must be assessed in accordance with the tax and legal rules of each jurisdiction.

Conclusion

The best jurisdiction for a real estate holding company depends above all on the location of the assets and the investor’s strategy.

The United Arab Emirates can be attractive for international investors and portfolios connected to the region. Singapore offers a highly credible jurisdiction for Asian investments, but certain real estate transactions are subject to specific duties.

Hong Kong can provide an interesting platform for Asian investments thanks to its territorial tax system. The United Kingdom remains particularly relevant when the assets or investors are connected to the UK market.

For an international real estate holding company, the best outcome rarely comes from simply choosing an “offshore” jurisdiction. It instead comes from creating a coherent structure between the holding company, local real estate companies, financing, taxation, and the investors’ tax residence.