Mishcon de Reya has responded to the Government consultation document, "Ensuring the fair taxation of residential property transactions", which covers:

  • The Government's new 15% SDLT charge on corporate purchases of UK residential properties worth over £2 million; and
  • The Government's proposed introduction of an annual charge and capital gains tax charge in relation to UK residential properties worth over £2 million in corporate structures. A headline summary of our concerns and recommendations is set out here.

These include our concerns about: perceived SDLT avoidance; pushing non-doms to hold UK property directly; the extension of the capital gains tax (CGT) regime to non-residents; dismantling corporate structures; and property development businesses.

Jonathan Legg and Ned El-Imad recently participated in Hamptons's SDLT roundtable to discuss these issues; click here for FT coverage.