Section 77A stamp duty restriction may not be as bad as you think
14th February 2025 | Posted in Articles, Stamp Duty, Stamp Duty Land Tax by Andrew Marr
Many reorganisations involve one company acquiring another company through a share for share exchange. Without a specific relief, stamp duty would…
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Construction work can be subject to stamp duty land tax (SDLT)
13th December 2024 | Posted in Articles, Stamp Duty Land Tax by Andrew Marr
It is fairly common for a lease to include an obligation to construct a building on the land which is the…
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Can share cancellation schemes save stamp duty?
11th October 2024 | Posted in Articles, Stamp Duty, Stamp Duty Land Tax by Andrew Marr
In its ‘stamp taxes on shares manual’ HMRC has the following to say on ‘cancellation schemes’: Under this scheme, the Court…
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Should non-residential SDLT rates be applied to scruffy dwellings?
7th October 2024 | Posted in Articles, Stamp Duty, Stamp Duty Land Tax by Andrew Marr
‘Tax refund outfits’ have been making hay over the last few years. Their ‘game’ works roughly as follows: 1. Sift through Rightmove…
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Lease extensions and the 3% surcharge
12th July 2024 | Posted in Articles, Stamp Duty, Stamp Duty Land Tax by Andrew Marr
The 3% SDLT surcharge has been with us for eight years now and the basic rules are as follows: 1. Trusts and…
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3% stamp duty land tax (SDLT) surcharge and linked transactions
5th July 2024 | Posted in Articles, Stamp Duty, Stamp Duty Land Tax by Andrew Marr
We recently considered a scenario where a property development company was considering acquiring a £3m house for development purposes. More accurately,…
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SDLT on in specie distributions
26th June 2024 | Posted in Articles, Stamp Duty, Stamp Duty Land Tax by Andrew Marr
There are often cases where it is beneficial to transfer assets from one company to another as a distribution. When property…
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Abolition of Multiple Dwellings Relief does not prevent reclaims being made
31st May 2024 | Posted in Articles, Stamp Duty, Stamp Duty Land Tax by Andrew Marr
On 6 March 2024 the Chancellor announced that Multiple Dwellings Relief (MDR) was to be abolished from 1 June 2024 (unless…
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The stamp duty land tax (SDLT) risk of de-enveloping property companies
12th April 2024 | Posted in Articles, Stamp Duty, Stamp Duty Land Tax by Andrew Marr
FA 2003 section 75A is the main piece of SDLT anti-avoidance legislation that HMRC has at its disposal to attack certain…
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Last chance saloon for Multiple Dwellings
18th March 2024 | Posted in Articles, Stamp Duty Land Tax by Andrew Marr
It was announced in the recent Budget that Multiple Dwellings Relief (MDR) will be abolished from 1 June 2024. Any contracts…
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