1 June 2012
The government has issued a consultation document giving further details of its proposals to charge capital gains tax on the disposal of residential property by companies and other ‘non-natural persons’ who are not resident in the UK, and to impose an annual charge on residential property owned by non-natural persons (wherever they are resident).
These measures, which will take effect from April 2013, are intended to counteract the avoidance of stamp duty land tax (SDLT) that can arise where residential property is held through companies or similar vehicles (‘enveloping’). They follow the imposition from 21 March 2012 of a 15% rate of SDLT on the acquisition of residential property costing more than £2 million by non-natural persons.