Budget 2012 announced a new higher 15 per cent rate of SDLT for residential property transactions by certain ‘non-natural persons'.
A posting on the ‘What’s New’ section of HMRC’s website on 23 March has provided some clarification of the meaning of ‘non-natural person', as follows:
“…broadly companies, collective investment schemes and partnerships with a member who is a company or a collective investment scheme…”
Two exclusions from the 15% charge are also confirmed:
“…for companies acting in its capacity as trustee of a settlement and for bona fide property developers who meet the qualifying conditions.”
Further clarification will no doubt follow with the publication of the Finance Bill, due on 29 March.