Scottish Ministers have introduced Regulations to amend schedule 1 of the Land and Buildings Transaction Tax (Scotland) Act 2013 by inserting a new paragraph 7A. From 1 April 2026, the creation, issue, transfer, redemption and cancellation of units in co‑ownership authorised contractual schemes (CoACS) will be exempt from LBTT. (legislation.gov.uk)
The Scottish Government’s Policy Note states that the exemption is targeted at investor‑level activity within CoACS and does not extend to the acquisition of land or buildings by the schemes themselves, which remains within LBTT. (legislation.gov.uk)
CoACS are described as investment schemes established under the Financial Services and Markets Act 2000 that can hold assets including land and property; scheme participants buy and sell ‘units’. The Regulations make clear that dealings in those units will be outside the LBTT charge. (legislation.gov.uk)
The instrument proceeded by affirmative procedure. On 3 February 2026 the Finance and Public Administration Committee took evidence from the Minister for Public Finance and recommended approval, and the Delegated Powers and Law Reform Committee raised no points requiring action. (parliament.scot)
In committee evidence, the Minister characterised investor‑level unit transactions as ‘tax‑neutral’ for LBTT and said the change removes a disincentive to invest in Scotland. The Scottish Fiscal Commission assessed the revenue impact as negligible and below its £5 million materiality threshold. (parliament.scot)
For asset managers, depositaries and pension funds using CoACS to pool UK property, the change streamlines subscriptions, redemptions and secondary transfers of units. However, any acquisition of a chargeable interest in Scottish property by a CoACS remains within scope of LBTT, with normal notification and payment rules applying where transactions are notifiable. (legislation.gov.uk)
The approach broadly mirrors treatment in England and Northern Ireland under Stamp Duty Land Tax: HMRC guidance treats a CoACS as a company and investors’ rights as shares, meaning investor‑level unit transactions are generally outside SDLT while property acquisitions remain chargeable. (gov.uk)
The exemption follows a Scottish Government consultation on property investment funds published on 11 July 2025, which sought views on the LBTT treatment of CoACS and included draft legislation. The consultation closed on 5 September 2025 and informed the final Regulations. (gov.scot)
LBTT is Scotland’s devolved property transactions tax, introduced in place of UK Stamp Duty Land Tax from 1 April 2015; it applies to acquisitions of chargeable interests in land and buildings. That context underlines that only investor‑level CoACS unit activity changes on 1 April 2026; property purchases by the schemes do not. (revenue.scot)