- HMRC warns against a tax avoidance scheme involving property transfers to an LLP and subsequent liquidation.
- The scheme aims to reduce or avoid CGT, SDLT, and inheritance tax.
- HMRC believes the scheme is ineffective due to specific tax regulations.
- New rules apply to MVLs from 30 October 2024, affecting CGT treatment.
- Finance Act 2003 prevents SDLT reduction through pre-arranged steps.
- Property rental businesses may not qualify for business property relief.
- The general anti-abuse rule may apply to the scheme.
- Non-natural persons owning residential property may face ATED charges.
- HMRC advises withdrawing from the scheme and settling tax affairs.
- Implications for scheme promoters are outlined in the Spotlight.
Source: icaew.com
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
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