In The Tower One St George Wharf Ltd v HMRC [2022] UKFTT 154 (TC) (3 May 2022) the First-tier Tribunal (FTT) held that SDLT was chargeable on the transfer of the lease of a residential property development within a group in circumstances where the transfer was part of a corporation tax scheme.
A group of companies were developing a site as residential property. The final part of the development was of a 50-floor tower block and the group wanted to transfer that building to a special purpose vehicle (SPV) in order to ring fence risks and potential liabilities and to provide greater financial flexibility. Following discussions with their tax advisors the group carried out a series of transactions on the same day intended to ‘step up’ the tax cost of the development so that the SPV would be treated as acquiring...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
In The Tower One St George Wharf Ltd v HMRC [2022] UKFTT 154 (TC) (3 May 2022) the First-tier Tribunal (FTT) held that SDLT was chargeable on the transfer of the lease of a residential property development within a group in circumstances where the transfer was part of a corporation tax scheme.
A group of companies were developing a site as residential property. The final part of the development was of a 50-floor tower block and the group wanted to transfer that building to a special purpose vehicle (SPV) in order to ring fence risks and potential liabilities and to provide greater financial flexibility. Following discussions with their tax advisors the group carried out a series of transactions on the same day intended to ‘step up’ the tax cost of the development so that the SPV would be treated as acquiring...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
