New Frontiers Ltd: A Mauritius GBC1 With UK REIT Status

Real Estate Investment Trusts have proved very popular world-wide as the way to structure listed investment holdings. The tax simplicity of having a flow through structure and only taxing the recipients of the Reit’s distributions has proved to be a success.  Osiris was recently tasked by New Frontiers Ltd to set up such a structure but with the ability to raise capital in South Africa.  We settled on a Mauritius GBC1 which was listed on the Stock Exchange of Mauritius with a secondary listing on the JSE.  As the focus of the investment vehicle was on investments into UK shopping centres it was decided to apply for UK REIT status.
This entailed approaching HMRC in the UK and the MRA in Mauritius and obtaining joint rulings to move management and control from Mauritius to the UK and thus obtaining UK REIT status from a particular date. This has been successfully achieved and provides a structure for New Frontiers with some interesting features:
  1. The ability to have a UK REIT whilst basing it on a GBC1 vehicle, the first such structure that we are aware of;
  2. The ability to do a cost effective initial listing and secondary listing on the JSE whilst still in growth phase;
  3. An effective structure going forwards with considerable more flexibility than if say a UK company had been used;

Whilst the same result could have been achieved with an AIM listing, the costs are considerable compared to the SEM with a similar initial result.

Should you require further information then please contact:
Daniel Romburgh |
Telephone: +230 650 4030