The new legislation in Finance Bill 2016 governing sales of UK land is now public and effective. The new rules are much more voluminous than is necessary to achieve the key objective of preventing non-residents from shielding trading profits using a treaty. The usual problems arise of widely worded charging provisions hitting unintended targets, together with uncertainty as to what precisely the new measures actually mean. More unexpectedly, the crucial provision which switches off treaty protection only does so in limited circumstances; and it seems that some profits from disposals of UK land held as trading stock after 4 July 2016 will remain outside the scope of UK tax.
