Partial Charities Relief - Finance Bill 2014

Summary and implications

The latest draft of the Finance Bill 2014, published on 27 March 2014, contains new provisions making it clear that partial charities relief is available when a charity jointly purchases property with a non-charity. The introduction of this legislation will make it difficult for anyone to argue that the decision in the Pollen Estate case should apply to other types of Stamp Duty Land Tax (SDLT) relief.

Background

In June 2013, the Court of Appeal overturned the decision of the Upper Tribunal in the case of Pollen Estate Trustee Company Limited and King's College London v HMRC and held that charities relief was available to a charity where it had jointly acquired property with a person other than a charity.