This year saw a number of key developments in commercial property tax. The June Budget saw an increase in the rate of CGT to 28% and the lifetime limit of entrepreneurs’ relief increased to £5 million; as well as a reduction in the writing-down rates for capital allowances. As expected, 2010 also saw further anti-avoidance legislation implemented. The scope of FA 2003 ss 75A–75C was extended to SDLT partnership transactions and scheme reference numbers were introduced to the SDLT disclosure regime. The decision in Subway One Ltd v HMRC also had an unexpected impact on the practical side of retail property transactions. 2011 will hopefully see a period of more stable property tax rates and a more confident market, with increased investment in property, particularly through REITs and PAIFs.
