As expected following the Chancellor's comments over the weekend, the Stamp Duty Land Tax (SDLT) focus was very much on expensive residential properties and most of the SDLT measures are concerned with residential properties over £2 million. From 22 March 2012, individuals will pay SDLT at the rate of 7% on buying such property.

And, effective from the day of the Budget, companies making such a purchase will pay at 15%. This much higher rate for companies (and certain other non-natural persons) is rooted in the perception that companies are used as a vehicle to avoid SDLT by allowing subsequent changes of ownership to be effected through share sales. The action against this 'enveloping' is punitive, as the Chancellor had warned it would be. It also does not apparently distinguish between special purposes companies and those companies (or funds) which hold multiple assets, or indeed are widely held.

And this is only round one. On the same basis, the Government also announced consultation on an annual levy where such properties are held by companies. The levy would be based on the value of the property, starting at £15,000 but increasing on a scale to £140,000 where the value is greater than £20m. More detail is no doubt to come, including whether the 15% entry charge and annual levy, which will commence in April 2013, will be cumulative.

Another SDLT measure is to amend Subsale relief to make it clear that it does not apply to the grant of options. This measure, which applies to residential and commercial property, is immediate and is to block a specific scheme which, for the record, most thought did not work anyway.

In addition, the Chancellor announced that SDLT will be included within the scope of the General Anti Avoidance Rule (GAAR),intended to be introduced next year, and that there will be consultation on simplifying certain aspects of the SDLT lease duty rules.

Although more detail is needed on the annual levy, these measures are perhaps more straightforward than the land rich property rules which many other jurisdictions have and which had been proposed by the Government in the UK twice before (in 2002 and 2007). The measures are tough on high-end residential property and, in a parting shot, the Chancellor's speech included a warning that he would not hesitate to take further action in this area swiftly, without notice and retrospectively.