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The Government is seeking views on a beneficial ownership register to increase the transparency of overseas investment in property and public contracts. Can as many people as possible respond!

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This call for evidence sets out proposals for a new beneficial ownership register of overseas companies that own UK property or participate in UK government procurement. It seeks views on the design of the policy and evidence on the possible effects of the policy.

This call for evidence will be of interest to:

  • overseas legal entities which own UK property or are considering buying UK property
  • overseas legal entities which are considering participating in UK central government procurement
  • professional advisers and service providers for overseas legal entities
  • estate agents
  • conveyancing solicitors
  • civil society and transparency campaigners

Ways to respond

Email to:


Write to:

Beneficial Ownership Team 
Department for Business, Energy and Industrial Strategy 
1 Victoria Street 


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Question 21: Do our proposals achieve the right balance between ensuring compliance and enabling overseas entities to maintain existing assets?

Needs to be answered with: Absulutely not. The proposals clearly provide no sanction of any consequence to non-compliance by any existing owner who does not plan to sell or any existing owner of a title that is not registered on land registry.
[IMO] This is clearly an attempt by a tory government to include loopholes that help their freinds and supporters.

Big loophole for current owners who don't plan to sell ..... [new money fwends]
No consequence of not registering except a note on LR.

Overseas entities that wish to sell property
57.Overseas entities that already own property in the UK when the law comes into force willbe given a year to comply with the new register’s requirements. After this year a notewill be put on an overseas entity’s property titles that will reflect that it will be unable tosell, lease or mortgage the property where it is not complying with the new law.
58.So at the end of the first year all overseas entities that own property in the UK,regardless of when they bought the property, will have a note on their title at theappropriate land register that will reflect the general prohibition from selling, leasing ormortgaging their property unless they are fully compliant with the new requirements.
59.This note on the title will be visible to prospective buyers during a search of the title. Thenote will flag up to third parties that the overseas entity will be unable to transfer title ofthe property if they are not fully compliant with the register. This compliance will berequired at the time the contract for sale is completed or settled. This would avoid asituation arising where a buyer entered into a contract to buy a property from a non-compliant overseas entity unaware that registration of their ownership would not bepossible because of non-compliance.
60.We propose that the transfer will be void if the overseas entity is not compliant with theregister requirements at the time the contract completes.

Big loophole for current owners of all the freehold (17%) that is not registered at LR ...  [old money fwends]

Unregistered land
61.These proposals will only apply to overseas entities that own land or property that isregistered. Not all land in the UK is currently registered. For example, 17% of freeholdland in England and Wales is unregistered. Any unregistered land currently owned byan overseas entity would not be subject to the new overseas register requirements.However, a transfer of unregistered land triggers registration, so the proposals will applyto an overseas entity buying unregistered land.

Both on p26.

BTW the usual gov procedure is that these documents are written by VIs [external accountants-lawyers-consultants who take fees for these arrangements] and the responses will be ignored except for a one line BS answer in the next document [responses to consultation]. Actually I'm surprised to see question 21 at all.


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Bump. VIs will of course make their responses, but all the more reason for learned HPCers to consider making inputs.

Consultation finishes 15 May.


The UK property market attracts a great deal of inward investment to the UK. This investment benefits the UK economy and supports the construction industry and a host of connected trades across the country. It is something that the UK government is committed to protecting. Therefore it is important to ensure the integrity and reputation of the UK property market.

The UK property market should be seen as fair, transparent and clean in order to attract the right investors and owners. Honest business should not fear that they are supporting criminal enterprise when investing in UK property. A higher level of transparency will boost investor confidence. 


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4 hours ago, GTFO said:

Can anyone post a submission they have made as a template for others. Short of time, but would like to help out.

Perhaps the great minds of HPC can formulate a template together?

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I don't think you have to respond to all 28 questions. I would single out these ones: 

Question 8: Do you have any information that is relevant to our assessment of the cost and benefits of the policy to businesses, society and the economy?

Question 9: What, if any, impact do you think that the proposed policy will have on the UK property market (residential and commercial)? Please describe the impacts and provide evidence.

Question 10: Do you agree that the duration of the period given to overseas entities to comply with the new requirements should be one year?

Question 11: Is a system of statutory restrictions and putting notes on the register, backed up by criminal offences, a comprehensive way to ensure compliance? 

Question 19: Is a requirement for an update every two years appropriate?

Question 20: Would a criminal offence be an appropriate way of enforcing the requirement to update information? 

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