Tax law

HM Revenue & Customs consultation on amending the SDLT transfer of rights or subsale rules

This consultation examines proposals to improve the rules to stop sales of SDLT avoidance schemes that attempt to rely on the transfer of rights rules, but ensure the rules give appropriate relief where commercially important.

HM Revenue & Customs consultation on simplifying IHT charges on Trusts

This consultation explores possible options for simplifying the calculation of the IHT periodic and exit charges on trusts that hold or dispose of relevant property.

General Anti-Abuse Rule (GAAR) consultation

This consultation seeks comments on the details of the proposal to introduce a GAAR, including draft legislation.

Taking forward a Scottish Land and Buildings Transaction Tax

This consultation paper seeks views on the Scottish Government's proposals for a Land and Buildings Transaction Tax for Scotland to replace the current UK Stamp Duty Land Tax from April 2015.

The Scottish Parliament will have new financial powers from 2015 over taxes on land and property transactions and on disposal to landfill.

This consultation is the first of three dealing with these devolved tax powers. The Scottish Government will consider its proposals for a Land and Buildings Transaction Tax for Scotland in the light of responses to the consultation paper, and then, in the autumn, introduce a Bill for the Scottish Parliament's consideration.

Ensuring the fair taxation of residential property transactions

This consultation is part of a package of measures that the government announced at budget 2012 to ensure that individuals and companies pay a fair share of tax on residential property transactions and to tackle avoidance, including the wrapping of property in corporate and other "envelopes".

The consultation specifically addresses the use of corporate and other envelopes to buy high value residential property and covers the budget announcements on:

  • An annual charge on residential properties valued over £2 million owned by certain "non-natural" persons (broadly companies, partnerships including companies and collective investment schemes); and
  • The extension of Capital Gains Tax (CGT) to the disposal by certain non-resident non-natural persons of residential property, interests in such property, or the envelopes in which they are held.

HM Treasury consultation on a disincorporation relief

The independent Office of Tax Simplification's (OTS) small business tax review, which was published in February 2012, identified a population of businesses that want to "disincorporate" - change their legal form from a limited company to self employed - but a number of tax charges and administrative issues might be preventing this. The OTS therefore recommended that the government introduce a relief against these tax charges alongside simplified administrative procedures for disincorporation. This consultation builds on the OTS's recommendation.