As a first step the company has applied for a listing on the Premier Marche of Euronext, the Paris bourse. The move follows legislation passed in France at the end of 2002, which permits real estate companies listed in France to elect into the new tax exempt regime.

Hammerson chairman Ron Spinney says the company's French business--which now accounts for nearly 30% of the total portfolio—-would become largely exempt from tax on income and capital gains in return for a one-off charge of approximately £70 million ($130 million), payable in four equal annual instalments.

"This is a very positive development, which should benefit Hammerson's operations in France and the group overall," Spinney says. And he made it clear that Hammerson would find a similar move for its UK portfolio attractive if the necessary legislation was put in place. "I am encouraged that the UK government has recently begun a consultation exercise, in which Hammerson is participating, in connection with the possible introduction of tax transparent property vehicles in the UK," he says.