New SDLT Rules

In March 2012, the UK government announced that it would be introducing a series of measures designed to counter perceived widespread avoidance of UK stamp duty land tax ("SDLT") using offshore corporate vehicles. The measures would include:

1. a new SDLT rate of 15% for purchases of high value residential UK real estate by "non-natural persons" (the "acquisition charge");
2. an annual charge on high value residential UK real estate held by non-natural persons (the "annual charge");
3. a charge to capital gains tax on the disposal of an interest in a non-natural person holding high value residential UK real estate (the "CGT charge").

The legislation implementing the acquisition charge was included in Finance Act 2012 and has had effect since 21 March 2012. Draft legislation to implement the annual charge was published shortly after the Chancellor's autumn statement in December 2012. The legislation will have effect from 1 April 2013. The draft