Downing Estate Planning Service
The Downing Estate Planning Service gives experienced investors an opportunity to protect their assets from inheritance tax. After two years, the investment should benefit from IHT relief, provided it is still held on death.
The service aims to deliver a consistent, but modest, level of return over the investment period – not guaranteed. To do this, it focuses on businesses in two distinct areas: asset-backed sectors and energy projects. Investors can choose to have exposure to just one or both, in which case they could gain exposure to over 70 underlying businesses.
The service includes a choice of two insurance options. The first, which is at no extra cost, protects the portfolio from losses of up to 20% for at least the first two years. Alternatively, there is a choice of life cover that could effectively make the investment IHT free from day one.
Downing is one of the UK’s larger providers of tax-efficient investments, managing more than £1 billion on behalf of 25,000 clients.
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- Free downside protection which protects initial net investment against falls in value of up to 20% (conditions apply)
- Optional life cover that effectively makes the portfolio IHT free from day one (conditions apply)
- Choice of focus on asset-backed or renewable energy businesses, or both
- 4% p.a. target return (not guaranteed)
- Option to have returns invested or paid out as regular distributions
- Minimum investment £25,000
Downing LLP was founded in 1986 and is a specialist investment management business with a focus on tax efficient investments. Today, the business has over 25,000 clients who collectively have over £1 billion invested with Downing. There are 50 investment professionals in Downing’s investment team.
The estate planning service is managed by an investment committee chaired by Chris Allner, a partner in Downing LLP with 35 years of industry experience, whose previous roles include Head of Private Equity at Octopus Investments, as well as various senior positions at a number of highly regarded city institutions. Supporting Chris are six experienced partners and heads of departments within Downing.
As at December 2019, the Downing investment team manages £457 million in the Estate Planning Service.
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The Downing Estate Planning Service seeks to provide investors with a return of 4% after charges (not guaranteed).
To help achieve this, it invests in two trading companies, each with a distinctive focus: Pulford Trading Limited (“Pulford”) focuses on asset-backed sectors, whilst Bagnall Energy Limited (“Bagnall”) focuses on energy projects. Both companies have in Downing’s view the potential to offer predictable returns and suitable asset backing and should qualify for BPR (Business Property Relief).
Investors can choose to invest in one, or split their investment across both. Pulford and Bagnall carry out their trade through over 70 underlying subsidiary businesses and investors will have exposure to these.
Downing invests in and lends to the businesses. The equity provides potential upside, whilst the loans give Downing greater control over the business. Downing looks to take a priority charge over the assets, to give investors a better chance of getting their money back if things don’t go to plan. Downing prefers to back proven management teams it has backed before, often following a management team from one project to the next.
1. Asset-backed focus: Pulford
Pulford’s subsidiary businesses operate from freehold premises, such as hotels, care homes and data centres. These have relatively stable revenues and an asset that underpins the investment value, so if things don’t go according to plan there will usually still be value in the freehold property, although this is not guaranteed.
Care homes are typically purpose-built with 60-90 beds in areas Downing consider to be attractive. Downing likes investing in Scotland as there is an element of support from the state that isn’t means-tested. All Pulford Trading’s Scottish care homes are run by one management team. Prior to making an investment in a new facility, Downing conducts market research to establish demand and potential fee levels.
Pulford also has an interest in a lending business, Downing Development Finance Limited, in which it has invested £45.7 million. The business makes secured loans to fund residential property developments, typically lending £1–£10 million per project. Downing is willing to take construction risk in a deal if it has first charge over the assets.
2. Renewable energy and energy infrastructure focus: Bagnall
Bagnall Energy Limited, previously known as Bagnall Renewables, carries its trade through a variety of subsidiaries in sectors with exposure to renewable energy and energy infrastructure assets, such as:
- Wind, solar, hydroelectric, and anaerobic digestion projects
- Sectors that enable the widespread rollout of renewable energy, such as reserve power, and energy storage
- Combined heat and power engines which process fuel to generate electricity and heat with lower wastage, thus enhancing energy efficiency
These businesses provide risk-managed opportunities for investment, as they usually have predictable revenue streams, often with access to government-approved subsidies, although these could be withdrawn in future.
The service targets a return of 4% per annum, after fees (excluding initial fees and discounts), over the medium term – not guaranteed.
To help achieve this, the annual management charge will only be payable at the end of each financial period if investors have received returns of at least 3% from an IHT company over that period.
Note that the annual fee is charged on an individual trading company basis, therefore it is possible for the charges to be taken on one company and not another.
Where returns are between 3% p.a. and 4% p.a., the charge is pro-rated on a 2:1 basis between the investor and Downing, to a maximum of 0.5% p.a., which is levied in full when gross returns are 4.5% p.a. or more. See example charges below:
The charge is not deferred. If the performance is not sufficient for the charge to be paid, in full or in part, in a particular period, it will be lost and never recouped.
Impact of IHT on investment returns
The table below shows illustrative returns for a £100,000 investment over 5, 10 and 15 years, with and without IHT relief.
|With IHT relief||Without IHT relief (subject to 40% IHT)|
|Illustrative net return||4%||4%||6%||8%|
The illustration with IHT relief shown above also includes the impact of the initial fee, and the Wealth Club discount applied to this offer, whereas the comparisons with other returns subject to IHT assumes no initial charges. Note this is not an illustration for the Downing estate planning service: please contact us for your personal illustration.
Current assets overview
Investors can choose a specific trading company or opt to split their investment between the two, for diversification.
Source: Downing as at 31 December 2019.
Source: Downing as at 31 December 2019.
Investors should note both Pulford and Bagnall have more than half of their assets invested in the their five largest subsidiary businesses, which adds a degree of concentration risk. However, the underlying subsidiaries themselves may also be diversified. Downing Development Finance, for instance, has itself made 39 investments to date.
Examples of assets by sector
Care homes (Pulford) – Magnus Care Group Ltd
As at December 2019, Pulford had £59.9 million invested within Magnus Care Group. Magnus Care Group is Pulford’s largest subsidiary business accounting for 13% of Pulford Trading’s assets.
Magnus Care Group owns and develops quality care homes. The business currently operates six care homes, all of which are now open and trading. The business offers considerable asset backing, Pulford Trading has security over the bricks and mortar of the care home properties, as well as other assets within the business, such as cash. Care homes include Bothwell Castle, located in an affluent area of Glasgow, and Beaumont Manor in Frinton-on-sea.
Solar (Bagnall) – Wensum Solar LLP
Wensum Solar LLP has developed a 6.9MW solar photovoltaic (PV) portfolio with the capacity to generate enough energy to power the equivalent of 1,900 UK homes for a whole year. The portfolio is split between 32 rooftop installations and one ground-mounted installation located across Lincolnshire and Norfolk. Revenues within the business are supported by Renewable Obligation Certificates (ROCs), a government-backed scheme to incentivise large scale renewable energy generation.
Pivot Power – recent investment and exit
Pivot Power is developing the world’s largest transmission-connected battery storage and electric vehicle charging network in the world. Downing first invested in the business at its inception in 2017. Its investment enabled Pivot Power to secure 45 sites across the UK where it can deploy its EV charging and connected grid battery technology. Following the successful acquisition of 45 sites across the UK, and after attracting national press coverage, Pivot Power drew the attention of numerous multinational businesses keen on acquiring it. Following a competitive bidding process led by Morgan Stanley, the business was sold to EDF Renewables UK.
Reserve power plant – example of a failure
Of course, things do not always work out. Downing has shared details of an investment which did not go to plan. Downing backed an established investor/developer to fund the construction and operation of four separate 18-20MW gas peaking plant projects with the intention of proving ‘reserve power’ to the National Grid. Delays to the development of one of the projects led to a breach of the loan facilities that were provided by Downing. The investor/developer was unable to remedy the breach or repay the loan facilities. As a result, Bagnall Energy acquired 100% ownership of all of the projects in 2019, with a write-down of £1.5m against the existing loan from Downing Estate Planning service of over £40m. The projects are now held in a subsidiary company of Bagnall Energy, called Magnus Assets One Ltd. Following this restructure, the construction works have been completed and the operations have been consolidated, so that all four projects are now operating effectively.
Both trading businesses have seen a reduction in their share prices in March 2020 following the outbreak of Covid-19. However, investors in the Downing Estate Planning Service should benefit from the 20% downside protection policy, subject to conditions. This means, in the event of death, the beneficiary should be protected from realising these losses.
Downing LLP, Companies House to 31 March 2020. Pulford launched in February 2013 and Bagnall in March 2013. Performance data shown is net of all ongoing charges. Please note these are unquoted companies and the share price is based on Downing’s own valuation. Remember, these investments are illiquid and can be difficult to sell and value. Past performance is not a guide to the future.
Downside protection insurance and life cover
Downing offers two forms of insurance: downside protection insurance and life cover.
Downside protection insurance
This is included at no extra cost where life cover is not chosen. It protects the initial net investment against a loss in value of up to 20% for those under age 90 at the time of death. The maximum claim is £100,000 per investor. The insurance policy is included (and paid for) by Downing for a minimum of two years. Other conditions apply.
This is optional. You can opt to pay an extra 2.25% in annual charges for the first two years and 40% of your original investment (i.e. the amount that could be subject to IHT) is insured if you die within that period. The policy is in trust so any payout should be made outside your estate.
There are a few conditions – you need to be under 85 years when you invest and you need to confirm a few health details. The maximum insurance per individual is £100,000 (equivalent to a £250,000 investment). Please check the terms and conditions for more details.
Access to your investment
Downing aims to provide access to funds twice a month, on ten days’ notice. This is subject to liquidity and is at Downing’s discretion. There are no charges or penalties for a partial or a full withdrawal. If you request a withdrawal, Downing will sell your shares at the current share price to a third party, wherever possible.
However, if it’s not possible to sell your shares to a third party, they may be repurchased by the trading companies – in which case, any profit may be subject to income tax. Bear in mind that the companies’ ability to repay will depend on liquidity.
Note that if your shares are sold to a third party (whether to provide distributions or a full withdrawal), a capital gain or loss could arise.
Also, any withdrawals from your portfolio will not benefit from IHT relief, unless another IHT exemption is used.
Risks – important
This, like all investments available through Wealth Club, is only for experienced investors happy to make their own investment decisions without advice.
The IHT service contains assets which are high risk and should only form part of a balanced portfolio, you should not invest money you cannot afford to lose. The service invests in illiquid assets which may be hard to sell or value. Before you invest, please carefully read the Risks and Commitments and the offer documents to ensure you fully understand the risks.
Tax rules can change and benefits depend on circumstances. Eligibility for BPR is assessed at the date of death and will depend on the companies in the portfolio remaining qualifying. Broadly speaking, you will need to have held a BPR qualifying stock for at least two years and still hold it on death to qualify.
More than 450 investors have passed away since the service launched, in every one of these cases, their investments have qualified for business property relief where the investor died after two years.
A previous Chancellor requested a review of IHT to simplify the tax system. A report was published in July 2019, but this has not yet led to any rule changes. Please remember, tax rules can and do change and benefits depend on circumstances.
A summary of the charges is shown below. Please see the provider’s documents for more details on the total fees and charges. If you would like a full breakdown of charges, or a personal illustration, please let us know.
|Full initial charge||4%|
|Wealth Club initial saving||2%|
|Net initial charge through Wealth Club||2%|
|Annual management charge||0.5%|
|Exit fee||—||Investee company charges|
|Annual charges||Up to 2.5%|
See example of the total charges over 5 years
With £457 million under management, the Downing Estate Planning Service is one of the leading inheritance tax investment services. Investors are given a choice of investing in one of two trading business or both. This adds a degree of control for investors and may appeal to those who favour one of the companies over the other.
The service has an appealing downside protection insurance policy which insures investors against losses of up to 20%, or a maximum of £100,000. The policy comes at no additional cost to investors and could be attractive for those seeking to shield their beneficiaries from the current period of economic uncertainty, as well as inheritance tax. The policy differentiates Downing from its peers.
Investors can also opt for an additional Life Cover policy which could make the investment effectively IHT free from day one. Downing has also enhanced the offer since our last review by removing its performance fee.
For experienced investors who concerned about the potential impact of inheritance tax on their estate and the current period of economic uncertainty, this could be a consideration. It may be of interest for those looking for a portfolio that can potentially offer BPR replacement relief. The service is established and has a track record of delivering modest and predictable growth whilst sheltering shareholders’ assets from inheritance tax: note past performance is not a guide to the future and tax rules can change: investors should form their own view.
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Wealth Club aims to make it easier for experienced investors to find information on – and apply for – tax-efficient investments. You should base your investment decision on the provider's documents and ensure you have read and fully understand them before investing. This review is a marketing communication. It is not advice or a personal or research recommendation to buy the investment mentioned. It does not satisfy legal requirements promoting investment research independence and is thus not subject to prohibitions on dealing ahead of its dissemination.
- Property & renewables
- Portfolio size
- £457.0 million
- Initial charge
- Saving via Wealth Club
- Net initial charge