PKF Francis Clark - Torquay Property Seminar - October 2016

Torquay Property Seminar
19th October 2016

Chairman’s Welcome
Andrew Squires - Partner

pkf-francisclark.co.uk
Housekeeping
Follow us on twitter:
@pkfFrancisClark
#TQPropertySeminar16

.
Merger with Princecroft Willis
• 1 April 2016
• 11 partner office
• 120 staff
• Turnover £6.8m
• 2 offices
- Poole
- New Forest

PKF Francis Clark
PKF Francis Clark offices

.
About the PKF network
• Global network of legally independent firms bound together
by a shared commitment to quality, integrity and the creation
of clarity in a complex regulatory environment.
• PKF is in the top 12 of worldwide accountancy networks
• PKF in the UK is ranked, by AccountancyAge Top 50 Firms,
as number 11 (operating as a network)
• Global network of over 300 independent member firms
• 440 locations in 150 countries
• A team of 14,000 including 2,600 partners
• Over $2.3bn worldwide revenue

Martin Hobbs became a Partner in the
Torquay office on 1 April 2016
What is new in PKF Francis Clark?

Programme
Coping with NRCGT, ATED and additional
rate SDLT– Karen Bowen
Capital Allowances & Commercial Property – Paul
Collings
VAT and Property – Richard Staunton

Coping with NRCGT, ATED
and additional rate SDLT
Karen Bowen

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Agenda
Annual Tax on Enveloped Dwellings (“ATED”)
• An overview
• Reliefs from the charge
• Tax filings and deadlines
• ATED-related capital gains
• Action points
SDLT – the 3% surcharge
• What it is and when it applies
• Example of a common scenario
• Reliefs
Non-residents capital gains tax (“NRCGT”)
• Compliance
• Transfers between connected persons
• Tax advice

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Annual tax on enveloped dwellings (ATED)
Initially introduced to counter perceived SDLT abuse.
Annual charge from 1 April 2013 for UK dwellings/residential property:
• owned by companies, corporate partners and collective investment
schemes,
• worth over £2m on 1 April 2012 or date of acquisition if later.
• Starting threshold for ATED reduced:
• From 1 April 2015 properties over £1m
• From 1 April 2016 properties over £500,000

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Annual tax on enveloped dwellings (ATED)
Taxable value
Annual
charge
2013/14
Annual charge
2014/15
Annual charge
2015/16 and
2016/17
Over £500,000 to
£1m
Not applicable Not applicable Not applicable/£3,500
Over £1m to £2m Not applicable Not applicable £7,000
Over £2m to £5m £15,000 £15,400 £23,350
Over £5m to £10m £35,000 £35,900 £54,450
Over £10m to £20m £70,000 £71,850 £109,050
More than £20m £140,000 £143,750 £218,200

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Reliefs from ATED charge
• Property rental business
• Dwellings open to the public
• Property developers
• Property traders
• Financial institutions acquiring in the course of lending
• Occupation by certain employees/partners
• Farmhouses
• Providers of social housing
Exempt: Charitable companies using dwelling for charitable purposes

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Non-qualifying individual occupation
Possible trap – any occupation by a non-qualifying individual will cause an
ATED chargeable period unless either the “farmhouse” or “open to public”
reliefs apply. This is the case even if the non-qualifying individual pays a full
market rent for occupation.
Non-qualifying individual includes:
• Individual connected to owner (e.g. who together with other connected
persons controls more than 50% of company).
• Partner of partnership
• Major participant (> 50%) in a collective investment scheme
• Settlor of trust which is connected to property owner
• Spouse, civil partner, sibling, lineal descendent or ancestor of a non-
qualifying individual and the spouses/civil partners of those individuals.

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ATED reporting/payment
ATED annual return or ATED relief declaration.
• Return must be filed by 30 April in the relevant tax year eg 2016/17 return
was due by 30 April 2016.
• A relief declaration form is needed for each type of relief relevant for the
company.
• Late filing penalties apply - £1,600 if 12 months late even if no ATED
payable!
• ATED payment also due by 30 April – 2016/17 payable by 30 April 2016.
• Adjustments must be made within 30 days of the end of the chargeable year.
• New acquisitions must be reported within 30 days (or 90 days for newly built
dwellings) unless a relevant ATED relief declaration form has already
submitted by company for the tax year.

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ATED – related capital gains
Applicable for any disposal of a UK residential property which has at any time
during the period of ownership been liable to an ATED charge.
Ownership period may include mix of ATED and non-ATED-CGT gains – can
be a very complicated calculation!
Valuation of property needed at date property came within scope of ATED:
• More than £2m: April 2013
• More than £1m to £2m: April 2015
• More than £500k to £1m April 2016
Gain applicable to ATED chargeable period taxed at 28% without indexation
relief.
Non ATED-CGT gain (after allowing indexation relief) is liable at corporation tax
rate (if UK company or NRCGT gain)

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Action points
• Be aware that ATED implications may arise when a non-natural
person acquires a dwelling-house for more than £500,000.
• Advise corporate purchaser to take tax advice regarding ATED –
especially to check if they need to file an ATED form/pay ATED
within 30 days of completion.
• Acquisitions include transfers of residential property on
incorporation of a business.

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SDLT bands and rates for dwellings
SDLT
rate
+3% surcharge
from 1 April
2016
From 4 December
2014 (proportionate)
SDLT band max
(without 3%)
Cumulative
total (without
3%)
SDLT band
max (with 3%)
Cumulative
total (with 3%)
Difference of 3%
0%
0% on
properties
less than
£40,000
£0 £0 £0 £0 £0 £0
0% 3% First £125,000 0 0 £3,750 £3,750 £3,750
2% 5%
Then £125,000
to £250,000
£2,500 £2,500 £6,250 £10,000 £7,500
5% 8%
Then £250,000
to £925,000
£33,750 £36,250 £54,000 £64,000 £27,750
10% 13%
Then £925,000
to £1.5m
£57,500 £93,750 £74,750 £138,750 £45,000
12% 15% Over £1.5m
Excess
over £1.5m
x 12%
+ 12% on
excess
Excess
over £1.5m
x 15%
+ 15% on
excess
+3% on
excess
Remember – companies acquiring residential property over £500,000 pay 15% on the full
purchase price if it has a non-qualifying use.
LBTT applies at the same rates for residences in Scotland. LTT is due to come into force from April
2018 in Wales.

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SDLT 3% surcharge
• Applies to all residential property purchases over £40,000 by companies or collective investment
schemes (unless acting as nominee for individual) and discretionary trusts.
• Generally applies to individuals acquiring an additional property (if they already own residential
property anywhere in the world)
• Relevant for all co-owners purchasing a dwelling if at least one co-owner has an additional
residential property at date of completion which is not excepted from the 3% charge.
• Spouses and civil partners treated as ‘one’
• Parents and minor children treated as ‘one’
• Residential property owned by a trust is an additional property for the life interest beneficiaries
acquiring residential property.
• Likewise, residential property owned by a life interest beneficiary is ‘additional property’ for
trustees of a life interest trust acquiring residential property.

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3% SDLT reliefs - individuals
The 3% surcharge is not applicable if:
• It replaces the individual’s former main residence (question of fact) sold within the last 36
months (transitional relief for purchases on or before 26 November 2018), or
• The only other property owned by the individual was inherited within the previous 36
months and the individual does not own more than 50% in the inherited property at date
of completion.
• The property is acquired for consideration of less than £40,000.
• Caravans, mobile homes and houseboats are not subject to the 3% surcharge and are
not regarded as ‘additional properties’.
• 3% is chargeable on purchase of additional property if former main residence is still
owned – but refund of 3% may be reclaimed if the main residence is sold within 36
months
• Watch co-owner’s position – may invalidate 3% relief!

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Example
Sally and Dave get engaged. They each own their own homes and, in
addition, Dave owns an investment property. They decide to place each of
their homes on the market to sell so they can buy a new home together.
They find a new home and Dave finds a buyer for his place. They decide to
go ahead with those transactions with Sally still needing to find a buyer for
her home.
The completion of the purchase of the new property and sale of Dave’s home
takes place on the same day.
Dave still has his investment property but he is replacing his former main
residence so the 3% SDLT surcharge would not normally apply. However,
Sally still has her property and they are co-owners, so the 3% SDLT applies
to the purchase of the new property for both of them.

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Example – possible solutions
Dave could acquire the new home in his sole name but;
• He may not be able to get a mortgage in his sole name,
• Sally may want to have an interest too – any future purchase of the property interest by
her (perhaps when she has sold her property) would be another SDLT event,
• Dave could gift her a share in the property later. But watch SDLT on transfer of a
mortgage to Sally. Also, any future gift must not be pre-agreed.
Option of Dave being sole owner is only possible if they are not married on the date of
completion!
Sally could gift her former home to a discretionary trust before completing on the new
purchase. But its value may be higher than the IHT nil-rate band and there are other tax
implications to consider.
Or they could pay the 3% SDLT in the hope that Sally will sell her home within 36
months at which time they can reclaim the 3% surcharge.
Relevance of GAAR and SDLT anti-avoidance legislation must be considered for all planning

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What is residential property?
Any building “suitable for use” as a dwelling or which is
in the “process of being constructed or adapted” for
such use along with gardens and grounds.
Uncertainty over ‘suitable for use’ and ‘process of
construction or adaptation’.
HMRC and Stamp Taxes Practitioners’ Group (STPG)
working to establish more clarity.

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SDLT reliefs
Always consider whether a residential property acquisition qualifies for SDLT relief:
• Acquisitions of 6 or more residential properties may be treated as non-residential property
so the lower commercial rates apply with no 3% surcharge.
• Alternatively, claim multiple dwellings relief – average of property values x number of
properties at residential rates (possible for acquisitions of more than 1 property). 3%
surcharge applies if averaged value is over £40,000.
• If the property acquired is a mix of residential and non-residential property, the non-
residential rates apply.
• A transfer of residential property from a partnership to a company qualifies for full SDLT
relief.
• A transfer of property between companies in the same group qualifies for full SDLT relief.
Planning for SDLT now an important consideration. If 3% surcharge looks to be
applicable, always double-check availability of reliefs and if in doubt suggest buyer
takes specialist advice.

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Non-residents capital gains tax (NRCGT)
• Non-resident owners disposing of UK residential property after 5 April 2015 (regardless of value
of property or its use – so different to ATED)
• Disposals must be reported to HMRC using online NRCGT form including:
• Owners not liable to NRCGT because they are liable only to ATED-related CGT
• Owners qualifying for main residence reliefs that would reduce chargeable
gain to nil.
• Owners that are selling at a loss.
• April 2015 rebasing (default) or time apportionment (election) if property owned on 5 April 2015
to calculate NRCGT gain/loss.
• NRCGT return filing deadline is 30 days following completion of conveyance.
• Late filing penalties apply - £1,600 if 12 months late even if no NRCGT payable!
• Payment also within 30 days unless tax reference held (SA700, SA900 or ATED references) – if
live tax reference, must also declare in the tax return for the year of disposal and pay on normal
due dates.

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Transfers between connected persons
Nil gain/loss transfers falling within section 288(3A) TCGA
1992 are not reportable, including:
• between spouses/civil partners,
• between companies in same “NRCGT group” (only
applicable if all companies are non-UK resident).

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Always recommend non-resident
vendors to take UK tax advice
• Date of exchange is the CGT date of disposal whereas completion date denotes the
deadline for NRCGT filing.
• If individual is leaving/coming back to the UK and is relying on split-year treatment,
he must meet at least one of the split-year Cases per the Statutory Residence Test.
• Foreign incorporated companies are UK resident if they are managed and controlled
in the UK – so may not be non-resident for NRCGT purposes.
• If a non-resident vendor resumes UK residence within 5 years of departure, further
CGT may be payable when he resumes UK residence.
• Alternative options for calculating the NRCGT position for properties owned on 5
April 2015. Need to consider which is the best one to use.
• Gifts by non-residents are disposals at market value for tax purposes.
• Filing deadline 30 days from date of completing conveyance. Penalties for late filing.

Capital Allowances &
Commercial Property
Paul Collings

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Why Capital Allowances?
• Allowances are “misunderstood”
• Capital allowances can be significant
• If you do get it wrong…..

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What are Capital Allowances?
• Companies and Individuals are assessed to tax
on profit:
Sales 100,000
Cost of Sales 60,000
Gross Profit 40,000
Insurance 5,000
Marketing 2,000
Postage etc. 1,000
Depreciation 4,000
Net Profit 28,000

.
Basic Tax Computation
Net Profit 28,000
Add back: Depreciation 4,000
Less: Capital Allowances (7,000)
Taxable Profit 25,000

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Capital Allowances
Different “Methods” of claiming
• Annual Investment Allowance - £200,000
• Writing Down Allowances – 18% or 8% reducing balance basis
• Capital Allowances claimed on a variety of items – reduce tax bills
- Machinery in a manufacturing business;
- Vans in delivery business
- Fixtures in a Commercial Building

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Annual Investment Allowance
Period from AIA
1/6 April 2008 £50,000
1/6 April 2010 £100,000
1/6 April 2012 £25,000
1 January 2013 £250,000
1/6 April 2014 £500,000
1 January 2016 £200,000
100% tax
relief

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What might constitute a fixture?
• Lighting;
• Air Conditioning;
• Heating Systems
Can claim capital allowances on these parts of a building;
But NOT the bricks and mortar.
When a building changes hands the fixtures will transfer.

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Fixtures
• New rules from 2012 & 2014 only relate to
fixtures
• Fixtures = plant & machinery installed/fixed to
building or land

.
For the Buyer to claim
• The Buyer must hold on “Capital Account”
• Since April 2014:
- Pooling Requirement
- Fixed Value Requirement
- Lose Capital Allowances??

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Fixtures - what properties?
Commercial properties
• Owner-occupied
• Landlords
• Furnished holiday lets
Not applicable to:
• Residential property
• Property developers (but their customers may be interested)

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Why are we here?

.
Why are we here?
• Property Prices Increasing
• Assessments being made of commercial
property;
• Formulaic Approach – replacement cost;
• Larger and larger claims being made – HMRC
wanted to “cap the cost”.

.
Properties most likely to gain….
Fixture-rich properties include:
• Hotels
• Restaurants/pubs
• Residential homes
• GP or dental surgeries
• Offices
• Furnished holiday lets

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Pooling Requirement
• “The vendor must include his expenditure in his
tax computations”
• A Ltd purchased a property in 2009 and is
selling it to B Ltd in 2017. B Ltd must have
added them to his tax computations.

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Pooling Requirement
• Must “Pool” – but only if entitled to claim;
• Gives HMRC visibility as to “cost”
• We might need to consider when the property
was acquired.

.
Fixed Value Requirement
• Must determine a value for the fixtures;
• Value is used in both computations;
• S198 election
• If can’t agree then possibility of going to
Tribunal – uncertainty and costs

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Pooling Requirement
• A Ltd purchased a property in 2009 and is
selling it to B Ltd in 2017. B Ltd must have
added them to his tax computations.
• One of the assets included is an air-con system
– cost £20,000.
• Might be anything £0 - £20,000

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Bad Example
• Owner Sells in October 2017 (acquired 2011).
• Property sold - £1million – potentially £350,000
of allowances.
• S198 claim at £40,000.
• Later realises that fixtures on a 2012 extension
were never claimed…..

.
Inability to Claim
• Owners may have acquired prior to 2008
• Integral Features
- An electrical system;
- A space or water heating system;
- A lift, escalator or moving walkway;
- External shading

.
Integral Features
• If incurred expenditure:
- Prior to April 2008 – cannot claim;
- After that date – you can claim;
- Integral Features – 8%
- Other fixtures – 18%

.
What is a fixture?
What is an Integral Feature?
8% Integral features
• Cold water systems
• Hot water systems
(boilers, storage, pumps,
pipework)
• Heating, ventilation & air
conditioning systems
• Electrical systems
• Lifts
18% Plant & machinery
• Sanitary appliances
(WCs, basins, showers,
etc)
• Fire fighting & warning
installations (fire alarms,
sprinklers, etc)
• Fitted kitchens

Integral Features and the
Pooling Requirement
• The vendor has NOT been able to claim relief;
• Provides an opportunity for the purchaser –
“tap in”
• Moving forward important to “grab” integral
features;

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Summary of Key Points
• Importance of the s198 Elections;
• Additional allowances might be available if pre-
2008;
• Possible Claim for Chattels;
• Critical that value “captured”

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Example 1
• Charlie bought an office building in 2002 and is
selling it in 2017;
• He meets all conditions for most fixtures;
• Charlie is NOT entitled to claim for integral features
• The new owner can look to claim in respect of
those integral features

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Example 2
• A Charity Owns a Freehold Block of Offices
• Now being sold - Acquired in 2010
• Never been entitled to claim
• No need for Fixed Value Requirement or Pooling
requirement

.
Example 3
• Oldco prepares accounts to 31 December
• Sells a property 1 November 2016
• Historically made losses – never bothered to look
into “fixtures” on extension in 2003.
• Must be included in 2013 tax comps – nil impact on
vendor.
• Integral features (pre-2008) claimed regardless

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Pooling
• Just because something is pooled doesn’t mean it
has to be shared…..
• On one extreme an old owner might include a zero
– old owner claims.
• Or – include maximum value – value in allowances
is passed onto the purchaser.

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Fixtures Elections
• Signed by both parties;
• Submitted to HMRC <2 years;
• Amount “fixture by fixture”.
• Cannot exceed cost;
• Binding on ALL parties.

.
Fixtures Elections
• Must NOT cover more than 1 property
• Only deals with fixtures –
Not Plant/Chattels
• Theoretically – “fixture by fixture” basis

.
What might be included on an election
• Assets that have always been General Fixtures
(e.g Toilets) X
• Assets that were general but now special rate (e.g.
lifts) X
• Assets (purchased since April 08) that are special
rate expenditure for both Buyer and Seller X

.
Elections - approach
• Negotiation between parties;
• Capped at a cost of a particular piece of
equipment;
• Vendor’s tax written down value??
• £1? “You are getting relief for all the integral
features on which I am unable to claim – but I am
keeping the rest”.

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CPSE Enquiries
32.2 – “Has the vendor claimed capital
allowances or allocated any expenditure on
fixtures to a capital allowances pool”
32.3 – “If you have not pooled any
expenditure……”

.
CPSE Enquiries
A better question might have been…
“If there is any capital allowances expenditure on
fixtures that you have not pooled......”

.
Example….
• Your client is buying a care home – CPSE
enquiries
• The vendor states that held “On Capital Account”.
• Queries ask “If you have not pooled any
expenditure” – client answers “No”
• All remaining queries (up to 32.8) are answered
“N/A”

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Example….
• “When we purchased the home, we agreed a
figure of £25,000 for fixtures and fittings. We also
claimed £10,000 for a new lift when we built an
extension in 2010, and £6,000 for new furniture at
the same time”.
• Advice?

.
Example….
• When was the property acquired? Was it pre-
2008?
• What did the £25,000 represent? Was an election
signed? Was it fixtures or just chattels? What did
the agreement say?
• Has there been an further capital expenditure?
What has been claimed on the extension?

VAT and Property
Richard Staunton

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Agenda
• VAT update – Brexit
• Pitfalls
• Case Study
• Questions

.
VAT Update – Brexit
What type of Brexit – does it matter?
• The death of VAT?!
• European tax
• Soft Brexit – price to pay for access to single market?
• Follow EC rules, CJEU affects UK VAT
• Hard Brexit – pick and choose VAT law?
• Could make law that EC directives followed, but what
about UK court decisions?

.
VAT Update - Brexit
What could be affected?
• Hard Brexit, medium soft Brexit or somewhere in
between
• Some UK exceptions mainly around zero rating
• Imports from EC, Exports to EC
• Distance selling
• Export of services
• Financial services

.
Pitfalls – Commercial buildings
• Standard rating applies to any sale of a new commercial
building within the first 3 years not just the first sale
• Charging VAT on commercial rents and not notifying
Option to Tax to HMRC within 30 days
• Opting to tax a building and not thinking through the
consequences
• Option to tax disapplied by purchaser
• Capital Goods Scheme adjustments

.
Pitfalls – Zero-rating
• Does the property qualify as a dwelling? Are there any
restrictions on separate use or disposal?
• Is the building constructed in accordance with the
planning permission?
• Retrospective planning permission - no longer a
solution? Cavendish Green
• Affects contractors and DIY

.
Pitfalls – Zero-rating
• Sub contractors working on relevant residential or relevant
charitable buildings (as opposed to dwellings) cannot zero-rate
their work, only the main contractor can zero-rate their services (if
certificate provided)
• How can you tell if the building qualifies for charitable use?

.
Pitfalls –
Transfer of a Going Concern
Advantage of TOGC is no VAT charge. Common obstacles:
• Immediately consecutive transfers
• Significant break in trade – property rental 3 month cycle?
• Purchaser not registered for VAT ‘Taxable person’
• Is a business being transferred or just assets?
• Will the purchaser use the assets to carry on same kind of
business?

.
Pitfalls –
Transfer of a Going Concern
Further issues arise where property is involved:
• Has the vendor opted to tax?
• Are any of the commercial properties new?
• If yes, purchaser will need to make and notify his option to tax prior
to the sale taking place
• Declaration by purchaser
• Could vendor revoke his option to tax?
• VAT incorrectly charged

.
Pitfalls – Option to tax
• Stays in place for 20 years
• If deregister will still apply, forward look will apply for
property sales, no exception
• If OTT not held VAT being charged not input tax?
• Lost OTT notifications, no longer needed
• What if HMRC ‘find’ an OTT later?

.
Case Study

.
Any questions?

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