Miscellaneous

Stamp duty land tax (SDLT)

Currently most transfers of an interest in land into, within or out of a partnership, are excluded from SDLT. Legislation will be introduced effective from Royal Assent to bring certain partnership transactions, where the partnership property includes an interest in UK land, within the scope of SDLT.

Further changes have been made to the SDLT regime to clarify points of uncertainty, counter avoidance and extend some reliefs.

Comment

Once again increases in SDLT rates were widely predicted but have not materialised so that the top rate of duty remains at 4%.


Merger

The Chancellor announced that the Inland Revenue and Customs and Excise are to merge.

Tax avoidance

New disclosure rules are to be introduced in relation to certain tax schemes. Broadly the rules will require tax scheme promoters to provide details of their schemes to the Inland Revenue shortly after the scheme is sold. The scheme will then be registered and a reference number allocated. Taxpayers using such schemes will then be required to include on their tax return the registration number of the scheme.

Extra funding will be provided to the Inland Revenue to help tackle fraud and tax avoidance.

Lloyd’s underwriters

Individual members of Lloyd’s who convert to underwriting through a corporate member of Lloyd’s will be able to set off trading losses from underwriting years before the transfer, against income derived from underwriting years after the transfer. They may also be able to defer liability to capital gains tax if assets held as funds are transferred to a company in exchange for shares.

Landfill tax

As previously announced the rate is increased from £14 to £15 per tonne with effect from 1 April 2004. The rate is to be increased by £3 per tonne in 2005 and by at least that amount in later years on the way to a medium to long-term rate of £35 per tonne.

The lower rate for inactive waste remains at £2 per tonne.

Property Investment Fund

The Chancellor has launched a consultation on the most appropriate structure for a new Property Investment Fund, a UK version of the successful US Real Estate Investment Trusts. It is hoped that the new fund will encourage more efficient investment in property and help to boost the private rented sector.

Immediate needs annuities

A measure is to be introduced to ensure the continued tax exemption of immediate needs annuity payments made by an insurance company for the provision of an individual’s long term care.