FA 2012 introduces some significant changes to SDLT, most notably the new 15% ‘enveloping’ charge on high-value residential property acquisitions by non-natural persons. The immediate introduction from the Budget date of this entirely new basis of taxing land transactions has given rise to a number of technical and practical issues for taxpayers, including concerns surrounding the identification of non-natural persons and the onerous conditions for bona fide businesses to escape the charge. The ongoing consultation on the taxation of residential property transactions will hopefully serve as a means of identifying and addressing these issues.
