01 Oct 2018

The Tax Committee has lobbied for seeding reliefs from stamp duty land tax (SDLT) and land and buildings transaction tax (LBTT) for both property authorised investment funds (PAIFs) and co-ownership authorised contractual schemes (CoACSs), together with clarity of treatment of CoACSs for both SDLT and LBTT more generally. The lack of such reliefs and clarity of treatment has been a significant barrier to the use of PAIFs and CoACSs as vehicles for property investment. Legislation is now due to be introduced for SDLT in Finance Bill 2016. The Tax Committee also lobbied for relief from LBTT on converting an existing property unit trust to a property authorised investment fund. The Scottish Government subsequently introduced relief with effect from 6 October 2015.

  • Response to Scottish Government consultation on Land and Building Transaction Tax – Property Investment Funds
  • Response to HMRC consultation: Stamp duty land tax: property investment funds
  • Letter to HM Treasury on SDLT seeding relief for PAIFs and CoACSs
  • The Land and Buildings Transaction Tax (Open-ended Investment Companies) (Scotland) Regulations 2015
  • Response to Scottish Government consultation on land and buildings transaction tax rules for property authorised investment funds
  • Letter to Scottish Government on LBTT seeding relief for PAIFs and LBTT treatment of CoACSs
  • Letter to Scottish Government on the need for LBTT relief on converting an existing property unit trust to a property authorised investment fund
  • Response to consultation on Stamp Duty Land Tax: rules for property investment funds
  • Letter to Chancellor on SDLT seeding relief