With regard to the 15% higher stamp duty land tax rate for acquisitions of residential property by certain non-natural persons, HMRC’s tax information and impact note ‘Stamp duty land tax rate: enveloping of high value residential properties’, published on 21 March, contained an error regarding the operative date for the measure.
The legislation makes it clear that the higher rate charge applies to all transactions where the contract is entered into on or after 21 March 2012.
The transitional rules can therefore only potentially apply to transactions whose contracts were entered into on or before 20 March 2012.