My client is a property rental company incorporated in the UK, the shares of which are wholly owned by the only director who permanently resides in Cuba. The director of the company is considering purchasing a UK residential property within the company worth £1m. What are the stamp duty land tax (SDLT) implications of the transaction?

Assuming the property is used or suitable for use as a dwelling, it will be subject to SDLT at the residential rates as per section 116 Finance Act 2003 (FA 2003). Acquisitions of dwellings by companies are always subject to the higher residential rate, ie, the additional 3% on top of the residential rates.