The disclosure regime applying to Stamp Duty Land Tax arrangements was extended, with effect from 1 April 2010, to include certain arrangements relating to Stamp Duty Land Tax where the subject matter involves residential property.

The extended regime will apply to certain arrangements where the subject matter of the arrangement is residential property with a market value of at least £1 million and mixed use property where the subject matter of the arrangements contains non-residential property with a market value of at least £5 million and/or residential property with a market value of at least £1 million.

Details of the relevant schemes will usually be notified to HMRC by the scheme promoter. However the user of the scheme must provide notification where the scheme is devised ‘in-house’, where the promoter is outside the UK and no promoter notifies, or where the information is to be covered by legal professional privilege.

When a scheme is notified, HMRC may issue an eight-digit Scheme Reference Number (SRN) to the person making the notification. A promoter to whom an SRN is issued must provide it to each client who implements the scheme. If there are other users of the scheme the client must provide the SRN to them.

When an SRN is received, either from HMRC or the scheme promoter, or a client of the promotor, the recipient is required to declare the use of the scheme to HMRC by submitting a form AAG4 (SDLT) within 30 days of entering into the first land transaction in connection with the scheme.

Further details are available at http://www.hmrc.gov.uk/aiu/form-aag4sdlt.htm