Look Through Company (“LTC”) structures are tax vehicles which have evolved from what was known as the Loss Attributing Qualifying Company (“LAQC”) regime. They are companies from a Companies Law perspective which have special tax status under the Inland Revenue Department’s rules. The key features of the LTC regime are:

  • Profits and Losses of the company are “attributed” through to the shareholders in accordance with their economic interest in the company
  • The shareholders are regarded as owning the assets of the company, rather than the company itself.

LTC’s, given the ability to “attribute” losses to shareholders, allow for tax benefits to be realised from investments such as investment properties, where different shareholdings are owned by a number of parties, i.e. husband and wife. They have also allowed investors to still receive such benefits even after the demise of the LAQC regime. There are a number of complex rules that surround the mechanics of the LTC regime and we would suggest that you get specific advice before incorporating and registering a company as a LTC. We are happy to provide guidance in this area if you would like to get in touch with us at Prudentia Law.