Property Tax Briefing March 2017 | Page 5

Corporation tax is of course lower than income tax and is getting lower still , which is a headline benefit to firms ( and they can claim some specific reliefs ): on the other hand , they will be placed under greater scrutiny and will fall under the new interest-related tax measures listed above .
7 . New Stamp Duty applications Stamp Duty Land Tax ( SDLT ), as we commented at the outset , has been comprehensively changed and some in the industry are struggling to deal with the new systems .
Private Dwellings Starting in April 2016 there has been a supplementary SDLT tax of 3 % when a residential property is bought .
Individuals can usually avoid paying this when they do not own any other residences worldwide ( as at the day of this transaction ). Of course most people who might be caught by this increased tax do already have private property .
Companies always pay it , with no exceptions .
8 . Commercial Property The basic SDLT was changed on commercial property transactions ( w . e . f . March 17 th 2016 ), such that the varying rate bands are applied in proportion , instead of you paying a flat rate based on the marginal rate that applies to the purchase price . This brings the treatment of private and commercial property in line with each other , albeit with differing rates .
The bands themselves were altered , and the net effect was to make commercial property acquisitions over £ 1,050,000 more costly .
Major Inheritance Tax clamp-down The changes to IHT from April 6th 2017 are very significant for non-doms . A typical residential ownership structure for these individuals until now has been :
Property owned by : ∨ Offshore company or partnership ∨ Shares owned by trust ∨ Beneficial owner ( s ) non-domiciled By owning shares rather than property directly , the person avoided UK inheritance tax on the dwelling . His or her holding was classed as ‘ excluded property ’.
HMRC will in future not exclude the ownership of a UK dwelling and in this example the shares will be taxed on the death of the beneficial owner .
It goes further than this , because there is no relief for those who let out their UK property , and even those who provide loans or security for a purchase will be subjected to IHT on the ‘ asset ’ at the time of their death .
9 . The need for valuations All of the foregoing means that UK property valuations may well be required ( as at April 2015 ) by non-doms for their NRCGT . If they have been long term UK residents ( for 15 out of the last 20 years ) then any overseas properties and assets may also require valuation in April 2017 , when they will be treated as UK domiciles for worldwide tax purposes .
Although CGT will become payable on overseas disposals , it will often be possible to use the April 2017 valuation of a ( personally-held ) asset and any previous gain will not be taxed .