Clarification of the operative date for the 15 per cent higher SDLT (Stamp Duty Land Tax) rate for acquisitions of residential property by certain non-natural persons. The Tax Information and Impact Note contain a small error regarding the operative date for the measure. It stated:
'Operative date
The measure will affect purchases of residential property costing more
than £2 million where the effective date of the transaction is 21
March 2012 or later and the person or persons acquiring the property
are among
the non-natural persons to whom the measure applies. There will be
transitional rules that will apply to transactions that would otherwise
be within
the higher rate charge but where the contract was completed and signed
by all parties to the transaction on or before 21 March 2012'’
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.