Key points
- HMRC is seeking to make SDLT paid on mixed-property purchases more equitable.
- Since 2013 SDLT has become more complex and taxpayers and solicitors are finding the rules increasingly difficult.
- There is a clear incentive for a taxpayer to find themselves on the commercial side of a mixed-use purchase.
- Deadline for responses to HMRC’s condoc is 22 February 2022.
Cliff edge tax thresholds are not great for anyone’s relationship with HMRC. A case in point is that parts of the stamp duty land tax rules can produce enormous swings in outcomes which turn on a small ambiguity and interpretation regardless of a taxpayer’s intent to cause malice or not.
HMRC is doing a good thing about this and in November 2021 released its consultation document (condoc) (tinyurl.com/2p9esr44) on potential fixes for two such key areas in property tax. The condoc is unambiguously called Stamp Duty...