Takeaway 1: Abolition of Multiple Dwellings Relief

The government has announced that from 1 June 2024, stamp duty land tax Multiple Dwelling Relief (“MDR”) will be abolished.

What is MDR?

MDR has been available to any purchaser (individual or company) buying two or more dwellings (flats, houses, etc)  in a single transaction, or linked transactions, and allows the purchaser to calculate the tax based on the average value of the residential properties purchased as opposed to their combined value. 

MDR is a tax relief, which was introduced by HMRC in 2011 to encourage investment in residential property in the UK and increase housing supply. The purpose of MDR was to reduce the tax payable on the purchase of a small portfolio of residential properties.  But in practice MDR has most often been claimed in relation to guest annexes, servants’ quarters etc. and has led to many spurious claims and tax tribunal challenges, most of which HMRC has won.

 Who is likely to be affected by the change?

Purchasers of residential property in England and Northern Ireland who acquire more than one dwelling in a single transaction or linked transactions, will be affected by the change.

This primarily affects landlords/ companies who purchase up to 5 residential properties in a single or linked transaction, e.g. several flats in a building or properties in an estate. Where 6 or more dwellings are acquired the loss of MDR will seldom be an issue because the lower, non-residential stamp duty land tax rates will apply.

Operative Date

From 1 June 2024, MDR will no longer be an available tax relief.

In respect of contracts, which have exchanged on or prior to 6 March 2024, MDR will be available, irrespective of when completion of the purchase takes places. However, this is subject to there being no change to the agreed contract after 6 March 2024.

Takeaway 2: Increase to VAT registration threshold

It was announced that from 1 April 2024, the annual taxable turnover threshold, by which a business is mandated to register for VAT will be increased from £85,000 to £90,000.

Takeaway 3: Reduction to Capital Gains Tax (CGT) rate for gains on residential property disposals

From 6 April 2024, the rate of CGT on any gains following the disposal of residential properties will be reduced from 28% to 24% in respect of individuals (where any gain falls within the taxpayer’s higher rate tax band), personal representatives and trustees. With regard to residential property gains which fall within the basic tax band of an individual, the rate will remain at 18%.

Takeaway 4: Significant changes for “Non-Doms” announced

The Proposed changes:

From April 2025 individuals who do not have a UK domicile their overseas income and gains with be exempt from UK Tax for the first 4 years of residence.  After 4 years, ‘non doms’ will be taxed on worldwide income and gains in the same way as any other UK resident.

For ‘non doms’ already in the UK there are transitional provisions which will apply before they pay UK tax on a worldwide basis.

Changes to Inheritance tax also announced to move to a residence based regime leading to individuals resident in the UK for 10 years subjected to UK IHT on their worldwide assets.  Consultation will be conducted on these changes. 

There may be planning opportunities prior to April 2025 once the draft legalisation has been published. 

If you require further Tax advice or have any queries, please contact Paul White (p.white@druces.com).