BOOK REVIEW: Stamp Duty Land Tax

This welcome addition to the literature on SDLT is directed at tax and property practitioners. It succeeds in the aim of giving a clear and useful explanation of SDLT. It has 20 chapters (316 pages plus appendix and index) with 211 subheadings.

The text is lucid; not a heavy read; directed at practicalities. The detail has value added with insights from experience. It does not just paraphrase legislation and HMRC guidance that some may find on the gov.uk website. Equally, it does not ramble so much through complexities that the reader cannot see the wood for the trees.

Seven chapters cover basics including chargeable consideration. Chapter 8 covers sub-sales. Two chapters concentrate on leases. Other chapters deal with corporate reliefs, partnerships, trusts, charities, residential reliefs, alternative property finance, anti-avoidance, returns, compliance and appeals.

There are tips on how to complete land transaction returns on various points although specimen paper forms are not included as an appendix for ease of reference. In reality, most SDLT returns are made online.

Brief indications are given of commercial context and comparison with other taxes. There are a few helpful examples (more would be better). The authors express their views on grey areas.

Publication was before the 3 December 2014 autumn statement changing from ‘slab’ to ‘slice’ SDLT rates for residential transactions. This change was well publicised. Being out of date on this aspect does not seriously impair the utility of the book. It deserves a second edition soon which will cover the Stamp Duty Land Tax Act 2015 and the Upper Tribunal’s decision in Project Blue (section 75A).

A slight niggle is that the contents pages do not indicate chapters divided into sections. Hence for chapter 17 you cannot see if ‘introduction’ is about section 75A, GAAR or DOTAS. Also, chapter 15 ends with enfranchisement of blocks of flats. However, a few minor points hardly detract from this interesting and well-presented book.

Stamp Duty Land Tax is now accompanied with an Autumn Statement 2014 Bulletin.

Gerald Moran is a partner at Hunters, Lincoln’s Inn