Readers’ forum: Charge to stamp duty land tax on life and reversionary interests

We have a number of UK resident clients of Italian origin who have various property interests in Italy.

It is not uncommon for Italian parents living in Italy to make an inter-vivos gift of their real property to their children while retaining the use and enjoyment of the property normally for life. Hence we have the creation of both an usufruct (similar to a life interest) which confers the use and enjoyment of the property to the parents and bare ownership which confers legal title to the property to the children but no right to its use or enjoyment until the death of the parents or expiry of the usufruct if earlier (legal ownership – reversionary interest).

The children may be likened to the remainderman in these arrangements. I believe that these types of arrangement do not create any form of...