15 per cent rate of SDLT for high-value residential property transactions
15 per cent rate of SDLT for high-value residential property transactions

The following Tax practice note provides comprehensive and up to date legal information covering:

  • 15 per cent rate of SDLT for high-value residential property transactions
  • When was the 15% rate introduced?
  • When does the 15% rate apply?
  • High-value property transaction
  • Apportionment for mixed use property
  • Interaction with other SDLT provisions
  • Are there any exclusions or reliefs?
  • In-force dates and transitional provisions

FORTHCOMING CHANGE relating to SDLT for non-residents buying residential property: As announced at Budget 2018, confirmed at Spring Budget 2020 and following a government consultation that ran until 6 May 2019, Finance Bill 2020–21 will include provisions for an SDLT surcharge of 2% for non-residents buying residential property in England and Northern Ireland. The surcharge will apply from 1 April 2021 (subject to transitional provisions). For more detail, see News Analyses: Draft Finance Bill 2020-21—new rates of stamp duty land tax for non-UK residents, Draft Finance Bill 2020–21—Tax analysis—New rates of stamp duty land tax (SDLT) for non-UK residents from 1 April 2021 and Reforming SDLT—the government consults on a non-UK resident surcharge.

FORTHCOMING CHANGE relating to housing co-operatives: Finance Bill 2020–21 will include provision for a new relief from ATED and the 15% rate of SDLT for certain qualifying housing co-operatives. The relief is aimed at housing co-operatives that are not registered providers of social housing. For more detail, see News Analysis: Draft Finance Bill 2020–21—Tax analysis—New reliefs from ATED and SDLT for housing co-operatives.

The higher rate of stamp duty land tax (SDLT) for high-value residential property (the 15% rate) was introduced as part of a package of measures aimed at making it less attractive to hold high-value UK residential property indirectly, eg through a company, in order to avoid or minimise taxes

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