SDLT pre-completion transactions and substantial performance: There are several complexities in G Goldsmith Ltd and another v HMRC [2024] UKFTT 927 (TC) (18 October) of interest to SDLT practitioners. It also shows some of the dangers which arise when advice is given on SDLT matters without a full understanding of the regime.
In essence the transaction here was a simple one. An individual purchased a property on behalf of his family and the property was converted into three separate apartments for onward sale. But there were two complexities. The first was that a significant amount of work was done on the property before the completion of the purchase. The second was that the contract to buy the property was transferred before completion to a company owned by the taxpayer.
HMRC argued that the contract had been substantially completed before the purchase because of the work which had been done. Although there...
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SDLT pre-completion transactions and substantial performance: There are several complexities in G Goldsmith Ltd and another v HMRC [2024] UKFTT 927 (TC) (18 October) of interest to SDLT practitioners. It also shows some of the dangers which arise when advice is given on SDLT matters without a full understanding of the regime.
In essence the transaction here was a simple one. An individual purchased a property on behalf of his family and the property was converted into three separate apartments for onward sale. But there were two complexities. The first was that a significant amount of work was done on the property before the completion of the purchase. The second was that the contract to buy the property was transferred before completion to a company owned by the taxpayer.
HMRC argued that the contract had been substantially completed before the purchase because of the work which had been done. Although there...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
