Collective enfranchisement
HMRC have remedied a legal issue which, in effect, had prevented an SDLT relief for collective enfranchisement from coming into force. Leaseholders acquiring their building's freehold under this process now benefit from a nil rate band (and, where that is exceeded, a threshold) which is multiplied by the number of flats in the building.
Our view
HMRC have reversed their own victory in a 2007 case but it may have limited immediate impact in that the value of residential freehold reversions do not in any event often exceed the current nil rate band of £175,000.
