A belated budget update, something that I missed at the time and maybe not everybody is aware of.
HMRC has announced that as part of the Investment Management Strategy, the Government will consult on the SDLT treatment of the seeding of property authorised investment funds and the wider SDLT treatment of co-ownership authorised contractual schemes.
In my experience life insurance companies, generally, want to move away from direct property holdings and instead invest in property collectives. However, the prospect of a charge to SDLT simply as a result of collectivization can prevent non - tax driven reorganizations from being contemplated. So it would be a definite step forward if some form of "seeding relief" as used to exist for unit trusts could be developed. It's my understanding that the old seeding relief was removed as people were using it to make property transactions (as distinct from reorganizations) SDLT free. So perhaps tricky to come up with something that is simple enough to be usable in "innocent" transactions but catches avoidance.
No comments:
Post a Comment