Lease extensions and the 3% surcharge

The 3% SDLT surcharge has been with us for eight years now and the basic rules are as follows: 1. Trusts and…

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3% stamp duty land tax (SDLT) surcharge and linked transactions

We recently considered a scenario where a property development company was considering acquiring a £3m house for development purposes. More accurately,…

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SDLT on in specie distributions

There are often cases where it is beneficial to transfer assets from one company to another as a distribution. When property…

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Child’s occupation of ATED property can lead to a nasty surprise

The Annual Tax on Enveloped Dwellings (‘ATED’) is a yearly charge applying to high-value residential property which is held by a…

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Be very careful when transferring property loans in a section 162 incorporation

Property business incorporations have been quite topical recently. The tax blogger Dan Neidle has attacked various mass marketed planning strategies in…

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Abolition of Multiple Dwellings Relief does not prevent reclaims being made

On 6 March 2024 the Chancellor announced that Multiple Dwellings Relief (MDR) was to be abolished from 1 June 2024 (unless…

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Foreign law matters when a non-UK resident company purchases its own shares

In UK law a company can purchase its own shares from its shareholders. The question then arises about how this should…

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Don’t forget about employee shareholder capital gain tax exemption

Employee shareholder status (ESS) was introduced on 6 April 2013 and was a very generous employee share incentive. Broadly it involved…

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Can you utilise your pensions annual allowance for a tax year where you have no earnings?

Most people are aware of the annual allowance which exists for pension contributions.  In years up to 2022/23 the annual allowance…

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Take a cheap mortgage from your company!

Perhaps surprisingly, HMRC has announced that the official rate of interest (ORI) for employee loans will remain at only 2.25% for…

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