The meaning of ‘land transaction’ is more important than ever. Paul Clark (Cripps) and John Shallcross (Blake Morgan) explore the issues, with examples.
SDLT is a tax on land transactions (FA 2003 s 42(1)) defined as ‘any acquisition of a chargeable interest’ (FA 2003 s 43(1)). An SDLT adviser must identify the land transactions and if there is more than one decide whether they are linked or part of an exchange. They cannot be both (FA 2003 s 47(1)).
This article focuses on the implications of identifying land transactions when applying the higher rate for additional transactions (HRAD or the 3% surcharge) and the non-UK resident surcharge (NRS or the 2% surcharge). All statutory references are to FA 2003 unless otherwise stated.
Although the meaning of ‘land transaction’ is central to the way in which SDLT operates reasonable views vary as to how to interpret...
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The meaning of ‘land transaction’ is more important than ever. Paul Clark (Cripps) and John Shallcross (Blake Morgan) explore the issues, with examples.
SDLT is a tax on land transactions (FA 2003 s 42(1)) defined as ‘any acquisition of a chargeable interest’ (FA 2003 s 43(1)). An SDLT adviser must identify the land transactions and if there is more than one decide whether they are linked or part of an exchange. They cannot be both (FA 2003 s 47(1)).
This article focuses on the implications of identifying land transactions when applying the higher rate for additional transactions (HRAD or the 3% surcharge) and the non-UK resident surcharge (NRS or the 2% surcharge). All statutory references are to FA 2003 unless otherwise stated.
Although the meaning of ‘land transaction’ is central to the way in which SDLT operates reasonable views vary as to how to interpret...
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:
