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PBR 2006: SDLT Anti-Avoidance

 
Patrick Cannon looks in detail at the SDLT anti-avoidance rules introduced in the Pre-Budget Report on 6 December 2006
 
The Stamp Duty Land Tax (Variation of the Finance Act 2003) Regulations 2006 (SI 2006 No 3237) introduced two new anti-avoidance rules effective from Wednesday 6 December 2006 (the 'relevant time'). One rule is intended to block SDLT schemes including sub-sales and lease variations of the type utilised by some taxpayers since the abolition of the relief for transfers into property unit trusts blocked the Jersey Property Unit Trusts (JPUT) schemes. The other anti-avoidance rule relates to schemes involving property investment partnerships. The Government has invited representations on the new Regulations and has said that account will be taken of any representations when drafting the provisions based on the regulations that are to be...
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