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FA 2013 changes to solve inheritance tax problems can cause unexpected stamp duty liabilities
KEY POINTS
- Changes to the impact of SDLT on assignments and subsales of land.
- Problems can arise when land is purchased and sold in tranches.
- Separate contracts may solve the problem.
- Inheritance tax changes to the allowability of a debt on an estate.
- Note that rearranging such debts on property can result in an SDLT liability.
It is often the case in tax that the sword stroke that attempts to cut away one problem can at the same time cause injury elsewhere. Unfortunately for tax practitioners in FA 2013 the double edge of the draughtsman’s blade has caused some issues related to stamp duty land tax (SDLT).
Perhaps doubly unfortunate is the fact that SDLT is not prominent in the field of vision of many practitioners and I...
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