In his December pre-Budget report, the Chancellor continued his assault on SDLT Saving Schemes, effectively closing off all the structures that had been notified to him under his recently introduced disclosure rules under which promoters have to notify HM Revenue and Customs of details of transactions where SDLT is ‘saved’.

The disclosure rules mean that no innovative structure is likely to survive for long in the future. Nevertheless, we are always looking for ways in which our clients can legitimately exploit legal nuances and will continue to do so.