March 23, 2012
Adam Blakemore stated “Although shareholders and participants in non-natural holders of U.K. residential property may wish to unwind such structures before the introduction of the annual charge in April 2013, the introduction of the new SDLT rate of 7 percent is likely to make it very challenging to achieve such an unwind without tax costs... Even if suitable methods of unwinding such structures can be located which do not involve significant tax costs, consideration will inevitably need to be given to the risk of such methods being targeted by retrospective tax legislation.”
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