Standard tags: tax

SDLT property: fixtures and chattels

A wooden door with a brass knocker stands between two columns, flanked by windows and potted plants. Text: "PRINCES GATE 71-72" and a sign, "THE OCCUPIER OF GLASGOW HOUSE," below foliage.
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HMRC has issued new guidance this week confirming its position on chattels claims in relation to Stamp Duty Land Tax (SDLT) liability.

Buyers often want to reduce their SDLT liability on a property purchase by arguing that some of the purchase price relates to chattels, i.e. tangible, moveable assets that are not permanently attached to the property such as furniture, paintings, rugs and curtains. 

However, HMRC is alive to this increasing trend, updating its guidance to confirm that any allocation to chattels will have to be properly documented in the sale contract. 

This will not be a simple exercise as sellers will need to consider the Capital Gains Tax (CGT) implications of selling valuable chattels as the gain on those assets will not be protected by principal private residence (PPR). As a result, conveyancers will want to carve out of their engagement advice relating to CGT.   

In the majority of cases consideration for the transaction will be correctly attributed to the land transaction, with no apportionment for chattels being appropriate. However, where a purchaser agrees to buy a property for a price that includes an amount properly attributed to chattels, that amount will not be subject to SDLT, as long as the purchaser can provide contemporaneous evidence from the conveyancing process that the attribution is genuine and arises from a separate negotiation for those chattels, for example by being expressly identified and priced in the sale contract. Simply showing that there were some chattels in the property when it was sold would not be considered sufficient evidence.

https://www.gov.uk/hmrc-internal-manuals/stamp-duty-land-tax-manual/sdltm04010

Rachel Reeves promises consultation on UK taxation of US LLCs

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London, UK - September 4 2025: exterior view of the Treasury in Westminster.

The FT’s report that Rachel Reeves has instructed the UK Treasury to examine the tax rules that can result in double taxation (see Anson article) for UK resident members of US LLCs is welcome. We look forward to the promised consultation.

On the wider picture of making UK plc attractive to wealthy individuals and families, who are internationally mobile nowadays, we can hope that this welcome signal prompts:

  • The UK Treasury to revisit the UK’s inheritance tax regime as well. For example, for those US citizens that Rachel Reeves wants to attract to the UK, the difference between the tax-free allowance for individuals in the US (a $15m lifetime exemption that increases annually for inflation) and the UK (£325,000) is material, even if planning (see FLP article) can bridge the gap.
  • The UK Government to streamline the visa rules (see more about immigration options) for wealthy individuals and families who can invest in the UK, as well as entrepreneurs and talented individuals who help drive growth.

She will promise that the Treasury will revisit tax rules which currently mean that people who receive income from a US limited liability company and move to the UK can face being taxed on both sides of the Atlantic. A consultation on the rules will be launched in due course.

https://www.ft.com/content/35d396e7-5590-4c65-9989-0c136e937fd7?accessToken=zwAAAZ2Ql-A_kc8105bnVZBMZdOZiQwTbpN_1w.MEQCIFYORv4gOaDblvDD22zQ3LbnzGNqrYLuZ89gR5XH76bcAiB6BWdkk666DRaVrlkpvxdvCSi4_M1q6NwU4zK3-5ZKmg&sharetype=gift&syn-25a6b1a6=1