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will also generally attract stamp duty at the rateof 0.5% of the purchase price.There are many exceptions to the requirementto pay stamp duty and SDRT and specificadvice should therefore be taken in all cases.2. Stamp Duty Land TaxStamp duty land tax (“SDLT”) is chargeable inrespect of most land and property transactionsinvolving any estate, interest, right or powerover land in the UK. In particular, it applies totransfers of freehold property and transfersand grants of leases. The rate of SDLT is asfollows:Non Residential or Mixed UsePurchase Price£150,000 or less 0%£150,000 to £250,000(this rate is reduced to 0%for first time users)Rate of SDLT1%£250,000 to £500,000 3%£500,000 or more 4%ResidentialPurchase Price£125,000 or less 0%£125,001 to £250,000 1%£250,001 to £500,000 3%£500,001 - £1m 4%£1m - £2m 5%Over £2m 7%Over £2m and purchase by“non-natural person”Rate of SDLT15%From 21 March 2012 SDLT is at 7% ontransactions in residential property whereconsideration exceeds £1m and from 22 March2012 SDLT is at 15% on purchase ofresidential property for over £2m by a nonnaturalperson. In this context non-naturalperson means that the purchaser is acompany, the acquisition is made by or onbehalf of the members of a partnership one ormore of whose members is a company, or theacquisition is made for the purposes of acollective investment scheme. There areexceptions in certain circumstances for acompany acting as a trustee of a settlementand for property developers.In addition to the above the Government is toconsult on the introduction of an annual chargeon UK residential property and shares orinterests in such property owned by nonnaturalpersons, with the charge likely to beeffective from 6 April 2013.Note as well that capital gains tax is likely to beextended to gains on the disposal of UKresidential property by a non-UK resident, nonnaturalperson, and shares or interests in the“non-natural” person from 6 April 2013.There is a different structure for chargingSDLT on the grant of a lease. The abovetables will remain applicable where a premiumis paid on a lease or a lease is assigned forconsideration. However where a new lease isgranted and a substantial rent is paid, inaddition to the above charges, SDLT ischargeable at 1% on the amount of the netpresent value (“NPV”) of the lease whichexceeds the threshold of £150,000 forcommercial leases and £125,000 forresidential leases. NPV is a tax concept whichis based on the rent payable on the lease witha slight percentage uplift to take into accountthe time value of money. If the NPV does notexceed the threshold, no SDLT is charged onthe rental element. There are many exceptionsto the requirement to pay SDLT and specificadvice should therefore be taken in all cases.4. Taxation of overseasindividualsThe tax position of overseas individualsworking in the UK is complicated and willdepend upon the particular circumstances ofthe relevant individual. The followingparagraphs contain only a brief summary ofthe rules:ResidenceThe current residence test applicable until 6April 2013 is based on case-law and HMRevenue and Customs practice and guidance.Under the current test to be regarded asresident in the UK for tax purposes you mustnormally be physically present in the country atsome time in the tax year. You will always beresident if you are here for 183 days or more inthe tax year (April 6th to April 5th). There arePAGE 13