From 1 July 2021 new rules applied to determine how vendors and purchasers allocate the purchase price to the various components of a transaction. Historically vendors and purchasers could take different tax positions and as long as there was justification for their position, then this could apply.

The new rules will radically change how the vendor and the purchaser perform these allocations and require symmetry. For example, they will apply to almost all transactions of commercial land and most business sales and force the vendor and the purchaser to use the same allocation.

Suited to:

Partners and senior staff members who advise on the tax consequences of significant capital transactions