HM Treasury and HM Revenue & Customs have published draft legislation for the Finance Bill 2013, on 11 December 2012.

The draft legislation puts more bones on the intention to charge an ongoing tax (Annual Residential Property Tax (ARPT)) on non-natural persons (NNPs) holdingUKresidential dwellings valued at over £2 million.

Rate of tax are yet to be published, but HMRC intend to charge ARPT at different rates according to whether the dwelling is valued at more than £2 million, £5 million, £10 million or £20 million.  The rates will be increased according to the consumer prices index each year.

There will be number of reliefs which owners of such properties ought to look at carefully, and consideration ought to be given to taking the property out of the NNP, and the attendant tax implications.

Abacus Solicitors specialise in the sale and purchase of high-value residential properties in England and Wales, and can advise on stamp duty land tax and Annual Residential Property Tax

 If you wish to discuss buying a house or flat in England or Wales valued at more than £2million please contact Sean Daly on 0161 833 0044 or by email at