More than half of the £400 billion of commercial property across Britain is believed to be held by investors and companies in tax havens overseas, The Times has learnt.

Property sources said that the practice of “managing tax” by holding shops, factories and offices in vehicles registered in Jersey, Guernsey, Gibraltar and the British Virgin Islands was widespread.

More than 70 per cent of the property owned by investment groups and funds is thought to be held offshore.

The details came as it emerged that Tesco had transferred the ownership of more than 80 of its supermarkets in the UK to joint ventures domiciled in the Cayman Islands.

The supermarket admitted that the move had helped it to become “more tax efficient” but vehemently denied suggestions that it had avoided paying tax on £500 million of profit from the deals.

A Tesco spokesman said: “Far from avoiding tax, Tesco is a top ten UK taxpayer contributing more than £1 billion to the Exchequer last year.”

Under the elaborate schemes in the Cayman Islands, Tesco has set up four separate joint ventures with the British Airways Pension Fund, British Land, Concensus Group and Topland.

It has sold parcels of stores to the joint ventures, which in turn charge the supermarket rents for their sites.

Tax partners said that the move allowed Tesco to build tax-free rental income at the joint ventures, which then could be lent back to the supermarket in the UK as working capital.

Tesco could even earn tax relief on interest payments to the joint ventures lending it money.

It pays capital gains tax on the profit made when the stores are transferred overseas.

Jan Ellis, tax partner at Blick Rothenberg, the chartered accountant, said: “British companies have traditionally been wary about being seen to manage their tax bill so aggressively because of the potentially negative reaction of customers.

“But Tesco is showing that this attitude is beginning to change. I'm sure other companies, like the major banks, are also using or looking at using similar schemes.”

John Knowles, managing director of corporate finance at DTZ, the property agent, added: “With Tesco it's not tax avoidance but tax management, making better use of their store estate to improve their financial performance.

"But everyone does it. In a way, it's like you or me holding cash in an Isa.”

Tesco values its property portfolio at £16 billion, while that of J Sainsbury was revalued last year at nearly £9 billion.

Sainsbury's announced plans for a sale and leaseback joint venture with Land Securities in November.

A spokesman for the supermarket chain insisted last night that all its stores were held in UK companies.

HM Revenue & Customs was caught up in the biggest controversy over offshore tax havens seven years ago.

It announced the sale of an estate of more than 600 buildings to Mapeley, a UK-registered property company.

It emerged later that the buildings had in fact been sold to Mapeley Steps, a Bermudan-based sister firm.

The Government is already thought to have lost out on hundreds of millions of pounds of potential stamp-duty revenues from commercial property owners who took advantage of tax-shelter loopholes before they were finally closed in October 2006.

Property owners put their holdings in offshore unit trusts where no stamp duty was payable on the transfer of assets into the trusts.

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