Residential Property
Section 75A
Land Proofing – Market Value Rules
Multiple Dwellings Relief
Incorporation of Property Businesses
SDLT Problems
Social Housing Providers
Residential SDLT: What’s Next?


Sean Randall – KPMG


Mike Dalton – Grant Thornton
Sara Maccallum – Boodle Hatfield
Simon Swann – Ashurst
Fiona Cole – KPMG
Toby Price – Deloitte
Georgina West – EY
Michael Thomas – Pump Court


8.45 – 9.20  Welcome

(Tea, coffee and pastries)

9.20 – 9.30  Chairman’s Introduction

Sean Randall, KPMG

9.30 – 10.15  Residential Property:  Cutting through the Complexity

– Review of the possible rates applicable
– What is residential property?
– Additional 3% rates
– The 15% rate engine
– Possible reliefs
– Recent changes
Sara Maccallum, Boodle Hatfield

10.15 – 11.00  Section 75A & other SDLT Anti-Avoidance Rules

– What does s 75A really mean?
– When does the “anti-avoidance rule” in group relief apply?
– Where is HMRC attacking using anti-avoidance rules?
– Furniss v Dawson, the GAAR and DOTAS, and their practical impacts on SDLT
Michael Thomas, Pump Court

11.00 – 11.20 Break

(Coffee, tea and biscuits)

11.20 – 11.45  Land Pooling Case Study

– Developers sitting on options to develop neighbouring land
– Pooling options into co-ownership
– Cost-sharing arrangement for past and future costs
– Exercise of options to assemble site
– Partition land following achievement of planning permissions
– Alternatives to pooling such as collaboration agreements, partnerships and JVCos
Toby Price, Deloitte

11.45 – 12.10  Multiple Dwellings Relief Case Study

– Do dwellings need to exist?
– How is the tax calculated?
– When is it worse to claim the relief?
– When does a claim rub against VAT?
Sean Randall, KPMG

12.10 – 12.55  All You Need to Know on the Market Value Rules

– When the rules (and their equivalents in LBTT and LTT) apply and when they do not
– Transfers to unit trusts and nominees
– Revenue authorities’ views on specific transactions
– Overview of the rules (currently in force and proposed) for stamp duty and what this might mean for groups
Georgina West, EY

12.55 – 14.00  Lunch

14.00 – 14.45  Incorporation of Property Businesses – Proceed with Caution

– Market value rule
– Schedule 15 partnership rules
– HMRC guidance / policy
– Check the history / facts!
– Claw back problems…?
– What about s 75A
– A tour around the UK
Mike Dalton, Grant Thornton

14.45 – 15.35  More SDLT Problems on Simon Swann’s Desk

– Further observations on section 75A
– Update on developments in VAT affecting SDLT liability
– Smallman: issues around substantial performance and repayments of SDLT
– Other problematic issues on commercial transactions
Simon Swann, Ashurst

15.35 – 15.55  Break

15.55 – 16.40  Social Housing Registered Providers

– Who are the registered providers?
– Conditions for RP relief
– Funding & practical issues
– RP relief vs. charities relief – who wins?
– Combining RP relief with other reliefs
Fiona Cole, KPMG

16.40 – 17.25  What’s Next for Residential SDLT?

– Is the surcharge stable?
– Is the mixed-use rule here to stay?
– How will the Overseas Buyers Levy work?
– What’s that coming over the hill – is it a land-rich charge?
Michael Thomas, Toby Price, Mike Dalton & Sara Maccallum
Facilitated by Sean Randall

17.25 – 17.30 Chairman’s Summation

Conference Closes

The conference will be followed by a drinks reception.


Gray’s Inn, London

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