The Co-ownership Contractual Schemes (Tax) Regulations 2025

Stamp duty land tax: contractual schemes

57.—(1) FA 2003(1) is amended as follows.

(2) In section 102A (co-ownership authorised contractual schemes)(2)—

(a) in the heading omit “authorised”;

(b) in subsection (2) omit “authorised”;

(c) after subsection (2) insert—

“(2A) In this Part, a “co-ownership contractual scheme” means—

(a) a co-ownership authorised contractual scheme, or

(b) a Reserved Investor Fund (Contractual Scheme).”;

(d) in subsection (3)—

(i) for “umbrella COACS” substitute “umbrella scheme”, and

(ii) omit “authorised”;

(e) in subsection (4) for “COACS” substitute “scheme”;

(f) in subsection (5)—

(i) for “COACS”, in both places it occurs, substitute “scheme”, and

(ii) omit “authorised”;

(g) in subsection (6) for “COACS” substitute “scheme”;

(h) in subsection (8), after the definition of “co-ownership scheme” insert—

““Reserved Investor Fund (Contractual Scheme)” has the meaning given by section 20 of the Finance (No.2) Act 2024.”;

(i) in subsection (9) after “contractual scheme” insert “or a Reserved Investor Fund (Contractual Scheme)”;

(j) in subsection (10) omit “authorised”;

(k) in subsection (11) omit “authorised”;

(l) in subsection (12), in paragraph (a) of the definition of “operator” omit “authorised”.

(3) In section 118(2) (meaning of “market value”)(3) for “COACS” substitute “co-ownership scheme”.

(4) In section 122 (index of defined expressions)(4)—

(a) in the table, in the first column for “COACS seeding relief” substitute “co-ownership scheme seeding relief”, and

(b) at the appropriate places insert—

“co-ownership contractual scheme	section 102A”;
“Reserved Investor Fund (Contractual Scheme)	section 102A”.

(5) In paragraph 2(6)(da) of Schedule 4A (stamp duty land tax: higher rate for certain transactions)(5) for “COACS” substitute “co-ownership scheme”.

(6) Schedule 9A (increased rates for non-resident transactions)(6) is amended as follows.

(7) In paragraph 7(4)(a) omit “authorised”.

(8) In the italic heading before paragraph 15 omit “authorised”.

(9) In paragraph 15, after sub-paragraph (2) insert—

“(3) A Reserved Investor Fund (Contractual Scheme) is not “non-resident” in relation to any chargeable transaction.”.

(10) In paragraph 11 of Schedule 17A (further provisions relating to leases)(7)—

(a) in sub-paragraph (3)(ba) for “COACS” substitute “co-ownership scheme”;

(b) in sub-paragraph (4) for “COACS” substitute “co-ownership scheme”;

(c) in sub-paragraph (5)(bb)—

(i) for “COACS” substitute “co-ownership scheme”, and

(ii) omit “authorised”;

(d) in sub-paragraph (6) for “COACS” substitute “co-ownership scheme”;

(e) in sub-paragraph (7) for “COACS”, in both places it occurs, substitute “co-ownership scheme”.

(1)

2003 c. 14.

(2)

Section 102A was added by paragraph 1 of Schedule 16 to the Finance Act 2016 (c. 24) and amended by S.I. 2019/689.

(3)

Section 118 was renumbered as s118(1) and s118(2) added by paragraph 10 of Schedule 16 to the Finance Act 2016 (c. 24).

(4)

Section 122 was amended by paragraphs 5(6), 22(7) and 25(4) of Schedule 39 to the Finance Act 2004 (c. 12), paragraph 6 of Schedule 8 to the Finance Act 2005 (c. 7), paragraph 5 of Schedule 30 to the Finance Act 2008 (c. 9), S.I. 2009/56, paragraph 23 of Schedule 3 to the Scotland Act 2012 (c. 11), paragraph 8 of Schedule 39 and paragraph 7 of Schedule 40 to the Finance Act 2013 (c. 29), paragraph 12 of Schedule 1 to the Stamp Duty Land Tax Act 2015 (c. 1), paragraph 11 of Schedule 16 to the Finance Act 2016 and paragraph 4 of Schedule 16 to the Finance Act 2021 (c. 26).

(5)

Schedule 4A was inserted by paragraph 4 of Schedule 35 to the Finance Act 2012 (c. 14). Paragraph 2 of Schedule 4A was amended by paragraph 12 of Schedule 16 to the Finance Act 2016, paragraph 7(2)(b) of Schedule 17 to the Finance Act 2021 and section 7(2)(a)(ii) of the Finance (No. 2) Act 2024 (c. 12).

(6)

Paragraphs 7 and 15 of Schedule 9A were inserted by paragraph 5 of Schedule 16 to the Finance Act 2021.

(7)

Paragraph 11 of Schedule 17A was inserted by paragraph 22(2) of Schedule 39 to the Finance Act 2004. Paragraph 11 was amended by paragraphs 7 and 12 of Schedule 10 to the Finance (No. 2) Act 2005 (c. 22), S.I. 2010/814 and paragraph 14 of Schedule 16 to the Finance Act 2016 (c. 24).