Can share cancellation schemes save stamp duty?

In its ‘stamp taxes on shares manual’ HMRC has the following to say on ‘cancellation schemes’: Under this scheme, the Court…

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Should non-residential SDLT rates be applied to scruffy dwellings?

‘Tax refund outfits’ have been making hay over the last few years. Their ‘game’ works roughly as follows: 1. Sift through Rightmove…

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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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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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The stamp duty land tax (SDLT) risk of de-enveloping property companies

FA 2003 section 75A is the main piece of SDLT anti-avoidance legislation that HMRC has at its disposal to attack certain…

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Capital gains tax and stamp duty land tax (SDLT)

There seems to be quite a lot of misunderstanding about the tax implications of property exchanges. Many people appear to have…

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Tax Tribunal rules that a paddock is non-residential for SDLT purposes

The issue Non-residential stamp duty land tax (SDLT) rates are significantly lower than residential SDLT rates for expensive properties. This leads…

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SDLT on six or more properties in linked transactions

The issue It is generally well understood that SDLT is charged at higher rates for residential property than for non-residential (or…

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