Briefing · 29 January 2026
Nearly 97,978 titles in England and Wales — worth about £460 billion — sit in offshore companies. In 44% of them, worth £190 billion, no human owner is on the public register.
Each square is 1% of offshore-owned property. Use the labels to filter the map.
The five colours
In 2022, overseas entities that own English or Welsh land had to register at Companies House and declare who really owns or controls them. Tax Policy Associates matched that register to HM Land Registry. The result is five buckets — only one of them is actually transparent.
Failure to register at all is falling. Claiming to have no beneficial owner is not. New filings in that bucket went from 9% of the pre-2023 stock to 19% in 2025.
Named cases
The original investigation mapped nearly 97,978 titles. Pin size follows price. Start in London, then cut by borough or trustee.
26 named titles
Value in the named cases, by district
The trust argument
The Register of Overseas Entities requires a human who owns more than 25%, or who exercises significant influence or control, to be named. The professional trust industry has adopted a narrower reading: that the client must control the trustee business itself, not the property sitting in the trust. Tax Policy Associates and the Department for Business and Trade say that reading is wrong.
1 · The asset
A house in Kensington, a City office, a logistics shed. The Land Registry title names an overseas company — not a person. From the street, nothing looks unusual.
A person is only a registrable beneficial owner if they exercise significant influence over the registered entity as a whole. A client of JTC or Apex, the argument goes, does not run the trustee company — they only direct “their” house. Therefore the trustee files itself.
Influence over the activities of the trust is enough. A letter of wishes that is routinely followed is significant influence. The Department for Business and Trade has said there is no loophole. Using the structure anyway is, on that view, systematic non-compliance — not clever lawyering.
Some trustees name a UK-incorporated company as the trust’s beneficiary. Automated checks then treat the chain as transparent — a UK company is in the picture, so the row looks green. That UK shell then files that it has no beneficial owners. Apex did this in Grimsby with Apex Consolidation Entity Ltd. The human is still missing; the paperwork looks fine.
The professional trustees
Of 201 professional trustees TPA reviewed, 181 had never once disclosed a true individual beneficial owner. Open a firm for the filing pattern. Where TPA named a building, it jumps to the map.
Deep cut · JTC
JTC is the largest user of the trustee-only filing in TPA’s data. Across roughly 1,800 UK titles the public register names the Jersey trustee, not the person who put the money in. The firm’s argument is the industry’s argument: the client does not control JTC the company, only “their” house, so the client is not a registrable beneficial owner. The Department for Business and Trade says that reading is wrong. A letter of wishes that is routinely followed is significant influence over the trust.
None of the high-value case studies TPA wrote up in the report text are labelled as JTC titles — the 1,800 sit in the bulk file, not the footnotes. That is the point of the scale: the pattern is industrial, not a handful of mansions.
| Trustee | Seat | UK titles | Human named | Pattern |
|---|---|---|---|---|
| Jersey | ~1,800 | 0% | Never names a human | |
| Jersey / group | Major book | 0% | UK-company blocker | |
| Jersey | Major book | 0% | Never names a human | |
| Jersey | Major book | 0% | Never names a human | |
| Jersey | Major book | 0% | Never names a human | |
| Isle of Man | Major book | 0% | Never names a human | |
| Offshore | Major book | 0% | Never names a human | |
| Offshore | Major book | 0% | Never names a human | |
| Switzerland / offshore | Major book | 0% | Never names a human | |
| Offshore | Major book | 0% | Never names a human | |
| Offshore | Major book | 0% | Never names a human | |
| Jersey | Major book | 0% | Never names a human | |
| Jersey | Major book | 2% | Names staff, not clients | |
| Guernsey | Major book | 22% | Sometimes names a human | |
| Offshore | Major book | 28% | Sometimes names a human | |
| Isle of Man | 5 | 0% | Never names a human | |
| Mauritius | 4 | 0% | Filed itself as its own owner |
Where the companies live
Crown dependencies dominate the stock. The worst rates of non-disclosure in the published tables sit elsewhere: Saudi Arabia at about 90%, Singapore at 70%, Denmark at 60% claiming no beneficial owner at all.
By far the largest jurisdiction for UK real estate held offshore, and the highest absolute number of hidden-ownership structures. Home to JTC, Ogier trustees, Langham Hall and a dense professional trust industry.
A major Channel Islands hub for corporate trustees holding English and Welsh titles, including Oak Trust — one of the few firms that sometimes names a human.
Long-standing holding jurisdiction for London residential property. Equiom and other Manx trustees appear throughout the hidden set.
Classic company-as-nominee jurisdiction. Named on Holland Park and Belgravia residential titles in the case studies.
2,114 companies in the dataset; about 70% are non-compliant on beneficial-ownership disclosure. Also the state TPA say should appear on the Blue Fin filing.
Fund-holding jurisdiction appearing in red and amber filings — including 81 Newgate Street, Caldecotte land, and the Dior flagship chain.
263 companies, of which about 60% claim to have no beneficial owner — an amber-heavy pattern TPA flag as statistically striking.
260 companies, roughly 90% non-compliant — the worst named rate in the published tables. Includes groups holding large residential portfolios.
A surprising number of French-registered companies either failed to register or claimed they had no beneficial owner.
Appears on unregistered grey titles such as 2 Whistler Square (Chelsea Barracks).
Home to ITL Trustees and Intercontinental Trust Limited, which filed that a trust company was its own beneficial owner.
Medco Holding / International Capital Trading on a £194m Kensington mews; Easa Saleh Al Gurg Group linked to the IBM South Bank building.
Why it matters · what to do
In the first two years Companies House issued 444 fines and collected 14. Hidden owners can sell the shares of a property-rich company in a tax haven and HMRC never sees the capital gain. The same opacity is how illicit money and sanctioned wealth park in bricks.
444
14
3%
Before 2015 (residential) and 2017 (commercial), a foreign company paid no UK capital gains tax when the building was sold. Non-doms could also wrap UK land in an offshore company and sidestep inheritance tax until 2017. Those routes are closed. Unwinding the old structures is expensive, so hundreds of billions remain offshore for reasons that no longer apply.
Today, selling the shares of a property-rich overseas company is still a UK CGT event. If HMRC cannot see the human, it cannot assess the gain. Every grey, red and blue company is a potential unpaid bill — and a place to park money that should not be here.
Civil powers, at scale
Companies House already has them. Send automated formal notices to every grey, red and blue filing. Most of the register would move if the letters were real.
Then freeze the title
If the notice is ignored, restrict the Land Registry title. The property cannot be sold or mortgaged until a human beneficial owner is named. That is a sanction the owner will feel.
Penalties that track the asset
A flat fine on a £793m Temple Place complex is theatre. Scale the penalty with value, then prosecute officers who still refuse.
Say the loophole does not exist
The Department for Business and Trade should put it in the guidance in words a trustee’s counsel cannot dance around. If needed, amend the statute.