The Chancellor's Budget rhetoric emphasised the UK's commitment to being a world leader in the asset management sector: the Chancellor stating that
HMRC has confirmed that, contrary to its previously held view, it now regards an LLP as a 'body corporate' for the purposes of both SDLT and stamp duty group relief.
In its 'What New?' section today, HMRC published a statement confirming a change of view on whether or not an LLP is a 'body corporate' for SDLT and stamp duty group relief purposes.
This year's Budget contains some headline grabbing changes in relation to residential property but there are a number of other notable points which are discussed below.
In a case last week, HSBC Holdings plc and Vidacos Nominees Ltd v HMRC (C-56907), the European Court of Justice (“ECJ”) held that the 1.5 UK stamp duty reserve tax ("SDRT") charge on the issue of shares into EU clearance systems is illegal.
Companies that have paid stamp duty reserve tax ("SDRT") on issuing shares into a clearance service on a listing on a non-UK stock exchange should take note of the Advocate General's opinion in the ECJ case of HSBC Holdings plc v HMRC (C-56907).