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New tax measures affecting UK residential property – The government's responses to the consultation

Three new tax measures were announced in the UK Budget on 21 March 2012 affecting UK residential property over £2 million owned by non-natural persons.

The aim of these measures was to counter perceived stamp duty avoidance by offshore vehicles and to encourage those in "envelopes" to "de-envelope". A consultation paper followed and HM Treasury published summary of responses on 11 December 2012 along with some (but not all) of the draft legislation to bring those measures into effect, which addressed many of the concerns addressed during the consultation period. Important revisions included the introduction of a rebasing mechanism for capital gains tax and alignment of the definition of "non-natural person" for the new measures – resulting in the exclusion of trusts from the new charges. The last piece of draft legislation was published on 31 January 2013, and the Finance Bill was published in March 2013.

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