PROPERTY TAXES

When is an interest in possession not an interest in possession? The answer to this question is one of several new developments reviewed by Edward Reed and Toby Ney (Macfarlanes).

HMRC has extended its losing streak against law firms that take leases through a subsidiary company. Chris Nyland (Scammell & Nyland) explores why HMRC keeps attacking the same structure, and how better to ensure that it doesn’t win.

Julie Howard and Kyra Motley (Boodle Hatfield) consider the options for both structuring and financing the ownership of UK residential property in the face of recent greater taxation and compliance burdens.

Julie Butler and Fred Butler (Butler & Co Alresford) examine an FTT case that denied a deduction for legal expenditure incurred defending rights to a number of assets ‘collectively’ when one of those assets was sold separately.

Max Schofield (3PB Barristers) examines five decisions of the First-tier Tribunal addressing appeals concerning SDLT multiple dwellings relief.

Marvin Reynolds and Jeffrey Webber (BDO) provide a practical guide to a relief for which claims are being actively challenged by HMRC.

Helen Coward (Charles Russell Speechlys) considers the important aspects of the draft legislation for the new residential property developer tax.

The consultation for the new residential property developer tax launched on 29 April. Lisa Bevan (Taylor Wessing) summarises the proposals and considers the questions that remain.