HMRC has issued some guidance on the special 15% Stamp Duty Land Tax charge which was announced in the Budget in respect of UK residential properties acquired by "non - natural persons" costing more than £2 million. The guidance does not really add much to the information previously published although it does make it clear that the charge will not apply to acquisitions by trustees - even corporate trustees.  

There are some anti avoidance rules of course, such as linked transactions and other techniques which might be used to circumvent the new rules but they do not give us much clue about the other charge which expected shortly - the annual charge on the holders of such property. Those details cannot be far away.  

The uncertainty about the transitional provisions was clarified last week by a press release from HMRC in which they confirmed that the higher rate charge applies to all transactions where the contract is entered into on or after 21 March 2012. It will not be necessary for the transaction to have been completed before Budget day to be protected under these provisions.