The Budget on 6 March contained one significant SDLT announcement which had not been seen coming, the abolition of multiple dwellings relief (“MDR”).
MDR was introduced to the SDLT regime in 2011 and provides relief for purchases of, as the name suggests, multiple dwellings acquired in, or as part of, the same transaction (or across linked transactions) and essentially means SDLT is calculated on...
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Tax Bite – Highlights of “Tax Day” – Stamp duty reform, and possible changes for EOTs?
Last Thursday 27 April was “Tax Administration and Maintenance Day”, which involved the publication of various consultations and proposals on tax measures, and the promise of more consultations to come.
Of most interest to those advising companies and their shareholders were:
The announcement that there will be...
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Property Tax Bite – SDLT sub-sale relief
In sub-sale transactions, the availability of relief from SDLT for the intermediate purchaser is crucial.
In most commercial sub-sales, the facts should support the relief being available, but as ever there are issues and pitfalls to watch out for. In this Tax Bite we very briefly summarise the key requirements for a “normal” sub-sale where A enters into a...
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Tax Bite – Stamp Duty on inserting a new holding company
This Tax Bite follows on from our Bite of 24 June, covering topical tax issues on demergers. As we explained in that Bite, there is a stamp duty relief, known as section 77 relief, which can apply where a new holding company is placed on top of an existing company / group, which is typically the first step in a demerger or other...
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HMRC have recently published new guidance (available here) on the VAT and SDLT implications of certain lease variations. In spite of HMRC’s statement that there is no change in policy, the VAT guidance represents a move away from what many advisers might previously have considered the position to be on certain lease amendments, where each party “gives something” to the other.
The new guidance has...
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As has been widely publicised, the Chancellor announced a temporary reduction in the rates of residential SDLT** as part of the government’s “mini-Budget”. The nil rate band for all residential property will be increased to £500,000 (from £125,000) effective immediately and until 31 March 2021, in the hopes of both supporting the housing market as it recovers from its hibernation during the...
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HMRC have introduced new temporary, emergency processes around stamping documents as a result of coronavirus measures, which new processes will remain in force until these measures end – although it is not clear at this stage what is meant by that.
What it does mean is that with immediate effect HMRC will not be physically stamping documents and the new processes, summarised below, should be used...
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