barmag67 Jan. 2016 | Page 18

Chambers property structures By David Webster, Partner in the Corporate and Commercial Team at Russell-Cooke During the last 10 to 15 years an increasing number of Chambers have sought new premises which better suit their needs. In addition to this move to more modern facilities, many have decided that, rather than renting from a third party landlord, Chambers should acquire a property outright I n a recent edition of the Barrister, my partner Scott Leonard described a structure commonly used to facilitate this type of acquisition - a bare trust / nominee arrangement where legal title is held by one or more trustees (commonly individual members of Chambers, or companies formed for the purpose and operated by members of Chambers), on trust for those members of Chambers who accept responsibility for funding the purchase. This article considers some of the matters that need to be attended to throughout the lifetime of these arrangements. Accounting records It may seem obvious, but it is crucial to keep up to date, detailed accounting records and to have a clear “audit trail” of monies going in and out of the structure. This is not necessarily as simple as it sounds. These arrangements cannot be treated in the same way as, for example, a company which has its own assets and liabilities – all income and outgoings have to be apportioned directly to the beneficial owners in their relevant shares. A detailed spreadsheet needs be set up at the outset, recording the interests of all participants including their liability for borrowing. This needs to be actively maintained. In most cases one would expect there to be relatively few, and fairly predictable, movements on a trust bank account, so it can be a fairly mechanical exercise – income will wish to assign the lease to a service company. In considering whether to consent to the assignment the trust will need to protect its position in the same manner as it would do with an unconnected tenant. This may mean that rent deposits and/or personal guarantees are required as a condition of giving consent. predominantly consist of quarterly rent payments, whilst outgoings will primarily be payments to mortgage lenders, together with more minor costs such as adviser’s fees. However, records will also need to be updated to deal with more “exceptional” items, for example changes in ownership of shares and related apportionments, or any overpayment of mortgage borrowing by a particular investor. Commonly these accounting functions are outsourced to the trust’s accountants or the SIPP provider. Separation between landlord and tenant It is essential to maintain a separation between Chambers as tenant and the Trust as landlord. One of the benefits of acquiring Chambers’ premises is that members become their own landlord. Nonetheless, all dealings between the trust and Chambers must be on arms’ length commercial terms. This is not simply a theoretical legal concern, failing to act in this way is likely to breach pensions legislation (assuming some mem