We responded to the first tranche of questions within the Government’s Business Rates Review, which covered aspects of the rules such as the multiplier, reliefs, empty rates, and the impact of capitalisation of rates into rents. We reiterated our primary concerns – that the business rates burden is too high and is not responding quickly enough to changes in market rents. We will now turn our attention to the second tranche of questions – which are due by the end of October.
We submitted comments in respect of the draft legislation which is introducing an SDLT surcharge on non-resident purchases buying residential property from April 2021. As well as some technical comments on the legislation, we took the opportunity to reiterate our concerns that these measures will hamper businesses which actually contribute to housing supply – such as build to rent providers and those developers that help fund their developments through off plan sales.
We responded to HMRC’s consultation on hybrids and other mismatches. We highlighted a number of areas where the rules could work better for fund structures – and in particular, noted that exempt investors should be able to invest collectively without incurring additional tax cost.
We responded to HMRC’s consultation in relation to tackling abuse in the Construction Industry Scheme. While we are supportive of HMRC’s efforts to tackle abuse, we were concerned that some of the proposals could have a detrimental impact on the construction industry. We also took the opportunity to highlight some challenges that arise in the CIS rules as a result of landlord tenant fit out contributions, as well as set out our ambitions for a group reporting process to ease the CIS compliance burden for larger groups.
We responded to HMRC’s consultation which proposes to introduce a new disclosure requirement for uncertain tax treatments for large business from next April. We expressed concern at the broad scope of the rules – especially at a time when businesses are already having to adapt to new ways of working. As well as calling for a delay to the implementation, we recommended that the scope of the rules be reduced, and that the definition of what is reportable within the rules is unambiguous and clear.
We responded to HM Treasury’s consultation on the treatment of asset holding companies in alternative fund structures – part of the government’s ongoing work to explore how the UK could better support the alternative fund sector. We set out the importance of ensuring that investors in collective investment structures achieve a similar tax outcome as if they had invested in the underlying real estate asset directly. To that end, we highlighted particular challenges with the UK’s tax rules in relation to withholding tax on interest and the relative attractiveness of the UK’s Substantial Shareholdings Exemption regime compared to other jurisdictions’ equivalent regimes for tax relief on gains.
The BPF responded to the Government’s Freeports Consultation. Our response emphasised the need to see Freeports in the context of a package of measures to help places around the UK level up.
We responded to the IASB’s consultation in relation to COVID-related rent concessions, our response highlights the scale of the impact on rents in the UK at the current time, and argues that landlords should also have the flexibility to recognise any rent concessions in the current accounting period, or continue to spread the remaining revenue over the remaining lease term – in line with the optionality being proposed for tenants.
We supported a statement alongside 16 other peer organisations across Europe which sets out how the real estate industry contributes to our lives and the economy – and the role we can play in the recovery from the Covid 19 crisis.
An analysis of the announcements pertinent to real estate in the 2020 Budget, including on High Streets, infrastructure, sustainability, and more.
We responded to the Government’s consultation on expanding the scope of the Trust Registration Service pursuant to the Fifth Money Laundering Directive. We raise concerns that the broad scope of the rules could inadvertently impose a disproportionate administrative burden on huge swathes of low-risk arrangements within real estate – and suggest some carve-outs to ensure that the rules are as well targeted as possible to the high-risk arrangements that the government is intending to capture.
We submitted representations to the Ministry of Housing, Communities & Local Government in response to their consultation on amendments to Part L (Conservation of fuel and power) and Part F (Ventilation) of the Building Regulations for new dwelling.