Scottish Government - LBTT and Property Investment Funds

The Scottish Government consulted over the summer of 2025 on Land and Building Transaction Tax (LBTT) and Property Investment Funds. This sought views on the following:

1. Draft legislation to exempt the exchange of participant rights within a Co-Ownership Authorised Contractual Schemes (CoACS) where Scottish property is held as an underlying asset of the scheme. 
2. An equivalent arrangement under LBTT to the Stamp Duty Land Tax (SDLT) regime for the Reserved Investor Fund (RIF).
3. LBTT seeding relief for Property Authorised Investment Funds (PAIFs), CoACS and RIFs.
4. Potential tax avoidance issues relating to the proposals above.

AREF submitted a response which was overseen by AREF's Tax Committee and Public Policy Committee.

Author

Jacqui Bungay

Head of Policy, AREF

Jacqui provides policy guidance and secretariat services to AREF’s Board and Management Committee as well as many of AREF's committees and working groups.

Jacqui joined AREF in 2014 after working for over 25 years in fund compliance, client relationships and administration in the trustee and depositary sector.