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Stamp Duty/SDLT changes

A measure is introduced with effect from midnight to enable the securitisation of alternative property finance assets to benefit from the same exemption from SDLT enjoyed on the securitisation of a conventional mortgage book. It is confirmed that the general anti-avoidance regulations introduced in the Pre-Budget Report will be replaced with an amended provision in the Finance Act 2007.

From 1 October, new zero carbon homes will benefit from an exemption from SDLT for the first £500,000 of the purchase price.

Other SDLT measures are of a minor technical nature, and relate to payment arrangements, the rate on exchanges of land, shared ownership leases and transfers of school land. A measure will also extend stamp duty reconstruction and acquisition relief so that these reliefs may more readily apply to a company holding shares in itself.

Amendments will be made to the stamp duty and SDRT exemptions in favour of intermediaries (brokers and dealers), and for stock loans and repo arrangements, so that they apply to certain transactions off-exchange. An aim of the amendments is to ensure that the exemption for intermediaries will be available to investment firms authorised under European Markets in Financial Instruments Directive (MiFID) to be implemented on 1 November this year.
 

Our view
Although these new measures are generally welcome, they are modest in scope and are unlikely to have a very wide impact.