United Kingdom

Stamp Taxes 

Is your organisation buying or selling land or shares, acquiring a business or undertaking a property or company reorganisation?

 

If so, there will be stamp taxes implications and with the highest rate of Stamp Duty Land Tax (SDLT) at 4 percent on land - this represents a substantial cost to your business.

 

We provide advice and guidance on all aspects of stamp duty, stamp duty land tax (SDLT) and stamp duty reserve tax (SDRT) , to help ensure your organisation does not pay more tax than necessary, and benefits from the tax reliefs available.

What's on your Mind?

 

  • Desire to minimise Stamp duty and SDLT costs on any deal or reorganisation using the reliefs legitimately available.
  • Need to create a tax-efficient structure for holding property and an exit strategy which maximises net proceeds.
  • Want to reduce tax costs around property leasing - every structure will have specific SDLT aspects to be considered.
  • Understand how to maximise tax reliefs when re-structuring the business as part of re-financing arrangements.
  • Need to ensure compliance obligations are met, given the complexity of the taxes.

 

What's in it for you?

 

  • Benefit from available reliefs and assurance that any structure is based on well-established principles.
  • A tax efficient structure which meets the commercial needs and manages the ongoing tax position.
  • The opportunity to maximise profits on an exit by considering the exit-route at the start.
  • Ongoing support and guidance when dealing with enquiries from HMRC.
  • An assurance that the necessary controls are in place to meet compliance and reporting obligations.

Why KPMG?

  • We have unrivalled experience in the field of Stamp Taxes; our team of experienced professionals include a number who held senior posts within HMRC Stamp Taxes.
  • Involvement in consultation on the rules for SDLT - all of the team were involved in this process.
  • Bespoke advice - based on our practical experience of property and share deals ranging from £1 million to multi-£billions.

 

Case Study

 

The challenge...

 

  • We were working on a public/private housing regeneration project with the potential for unexpected SDLT charges to arise. Since the financial viability of the project was based on assumptions about the SDLT costs, then any additional charges would have meant the project would not go ahead.
  • The structure was such that there was a considerable risk of the building works of £200M being brought within the charge.

 

The solution.

 

  • We identified the risks and suggested variations to the structure to manage these risks. Since many of the points of technical interpretation were without precedent we consulted with HMRC in setting out our analysis of the rules, our arguments that concessions should apply and seeking clearance.

 

The outcome.

 

  • We achieved a favourable opinion from HMRC which meant the charge was limited to the land price alone, enabling the project to proceed without the risk of any further unplanned cost.

Contact

Gordon Keenay

 

Senior Manager
KPMG LLP (UK)

 

020 7311 1775
gordon.keenay@kpmg.co.uk