HMRC’s recently published guidance on SDLT and de-enveloping transactions is distinctly unhelpful, writes Marc Selby
The guidance published by HMRC on 20 December 2013 entitled Stamp duty land tax on de-enveloping transactions is distinctly unhelpful.
‘De-enveloping’ is the term used by HMRC and those who advise on property owning structures for the extraction of high value residential property from companies and other entities (which include partnerships with corporate members and collective investment schemes) which are subject to annual tax on enveloped dwellings (ATED) introduced in FA 2013 in relation to single dwellings with a value of more than £2m owned by such entities on or after 1 April 2013.
Prior to the introduction of ATED and more particularly the introduction of the penal 15% rate of SDLT with...
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