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Analysis – SDLT on options

Marc Selby reviews HMRC-approved answers to a question concerning SDLT on options

This is the second article in the series on the Q&A Session in the STPG Conference 2009 the first of which (Issue 1021 22 March 2010) covered three Q&As.

This article sets out a single composite question on SDLT on Options which contains four alternative and interesting conundrums each of which has a different answer.

As previously the answers have been prepared and cleared for publication by HMRC and we are grateful to Nick John of HMRC Stamp Taxes for his co-operation in this regard.

Question: SDLT on options

Mr Green owns Greenacre (which he wants to sell) and also owns Yellowacre (which he wants to retain). Access to Yellowacre is currently via part of Greenacre.

The potential buyer of Greenacre is Mr Black who owns Blackacre and a small surplus area...

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