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By Mark Preston, Executive Trustee & CEO, Grosvenor
I feel very strongly about the moral duty of all individuals and businesses to pay their fair share of tax and abide by the rule of law that determines it. So does the Duke of Westminster and the Grosvenor family.
Our approach to tax is governed by a tax policy which can be read here, whereas in this article, I wish to set out some facts about our ownership structure and the way we ensure that the taxes we pay live up to the moral duty I speak of.
Who we are:
Grosvenor is an international organisation which represents the Grosvenor family and whose purpose is to deliver lasting commercial, social and environmental benefit.
Our activities include developing, managing, and investing in international urban property across many of the world’s leading cities. In the food and agtech sector our growing investment portfolio includes some of the industry’s most innovative businesses. We manage rural estates and their environmentally sensitive habitats, while supporting charitable initiatives targeted at vulnerable young people.
Our size and value:
We believe in the importance of transparency and accountability which is why for over 20 years – despite being privately-owned, we have published Annual Reviews and Financial Statements in a way that is comparable to listed companies. Our published information now accounts for the full breadth of Grosvenor’s commercial activities, and our most recent Annual Review published in May 2022 is available here. Within our reviews we also publish information about the commercial taxes we pay around the world.
Grosvenor’s ownership structure is the foundation of our long-term investment approach:
In common with many other family-owned enterprises, Grosvenor’s commercial business assets are owned by a series of UK resident (i.e. onshore) trusts. This ensures continuity of ownership, administration and management across the generations. In providing stability, it enables a genuine long-term value creation investment approach to flourish so that decisions are instinctively made to balance today’s needs while taking responsibility for those of future generations – ensuring that positive commercial, social and environmental outcomes are lasting.
Tax paid by the Trusts:
The UK resident trusts are liable to pay all applicable taxes including income tax, capital gains tax and inheritance tax (IHT).
With regards to the latter, instead of a payment of 40% inheritance tax upon death, the majority of the trusts pay a recurring rate of 6% every 10 years - the same that is levied on all UK trusts of their type. This means that over a full lifetime, the trusts will pay this tax many times over, with the added advantage to the UK Exchequer of its regular, effectively in-advance payment schedule. The remaining trusts will be subject to 40% IHT on the death of the specific beneficiary.
As Grosvenor family members, who are the beneficiaries of the trusts, are all UK resident – as their predecessors have been for nearly 1,000 years - they pay UK taxes in the same way as the rest of the UK population, while being entitled to the same exemptions. By way of example, the personal assets left by the 6th Duke of Westminster to his widow upon his death in 2016 were exempt from inheritance tax – exactly in the same way as they would have applied to any other UK married couple. On her death, inheritance tax will be due in the usual manner.
In addition to the main UK-based trusts there are two small non-UK resident trusts which were established over 55 years ago to acquire some non-UK assets. These trusts hold less than 1% of the value of Grosvenor’s assets but are not connected to the commercial activities of the organisation. No family member has received any benefit derived from these but, as UK residents, if they ever did then the value of the benefit received would be subject to tax in the UK. These trusts are also subject to the 10-yearly inheritance tax charge.
Tax related to our commercial activities:
All income and gains from our property activities are taxed in accordance with the rules of the country where the property is located.
Across our commercial activities we occasionally invest in ventures with other investors which are established in jurisdictions that do not create an additional layer of tax. This is done to prevent the investors being subjected to double taxation. Otherwise, we are careful to ensure that our ownership of overseas assets is through vehicles incorporated in the same country as the asset.