The Autumn Budget 2021 only included three stamp taxes announcements, none of which introduced new or substantive changes. These three stamp taxes announcements provided:Confirmation that the first three Freeport sites are about to become operational;
- For future amendments to be made to the existing loan capital exemptions, when the Government responds to the 2021 securitisation consultation; and
- Confirmation of the start date for the new Asset Holding Company tax regime.
Stamp Duty Land Tax - Freeports
At Spring Budget 2021, the government announced 8 Freeports in 8 English regions, which are intended to encourage businesses to create new global trade hubs.
At Autumn Budget 2021, the government announced that the first three Freeport sites will be located in Humber, Teesside and Thames, and that those Freeports will be able to begin initial operations from November.
Acquisitions of land related assets for qualifying purposes within freeport areas can be exempted entirely from stamp duty land lax (in addition, there can be a variety of other tax benefits for businesses in these areas). The SDLT relief is only available to the extent the land is to be used for a ‘qualifying manner’, which excludes residential use. Broadly the land must either be used in the course of a commercial trade or profession; or be developed or redeveloped for the same use, or rented out. The relief is also subject to a ‘control period’ of up to 3 years from the land being acquired and may be clawed back if, and to the extent, the usage changes.
Stamp Duty/Stamp Duty Reserve Tax
Taxation of securitisations and insurance-linked securities
In March 2021, the government published a consultation on reform of the taxation of securitisation companies, the responses to which have not yet been published. The government confirmed in the Autumn Budget that it will legislate in Finance Bill 2021-22 to introduce a power to enable future changes to be made to the Stamp Duty loan capital exemption as it applies to securitisations.
However, there were no immediate policy (or substantial) changes to the stamp duty or SDRT legislation announced in the Budget.
New tax regime for asset holding companies (AHCs)
The government consulted on a new tax regime for UK asset holding companies. In response to the consultation, it was announced in July 20201 that the tax regime will exempt repurchases of share and loan capital by a Qualified Asset Holding Company.
It was confirmed in the Autumn Budget that the new regime will have a start date of 1 April 2022.
If you would like to discuss this further, please get in touch with Jamie Ward or your usual PwC Stamp Taxes contact.