Stamp Duty Land Tax – Sale and sub-sale of large development site – Application of Finance Act 2003, section 45(3), in the form current in 2007 and 2008 – Sub-sale to financial institution – Interpretation and application of Finance Act 2003, . .
Stamp Duty Land Tax – avoidance scheme – use of unlimited company to contract for purchase of property, followed by reduction of capital and dividend in specie of the property acquired to its parent company – claim for exemption from SDLT under section 45(3) Finance Act 2003 (sub-sale relief) – whether unlimited company had complied … Continue reading Vardy Proprties and Another v Revenue and Customs: FTTTx 6 Sep 2012
The company had purchased the site of the former Chelsea barracks. It was in turn owned by the Qatari sovereign wealth fund, which financed the purchase by a Sharia compliant loan scheme, which was implemented creating a lease and buy back arrangement. The company now appealed against a finding that it was liable to stamp … Continue reading Project Blue Ltd v Revenue and Customs: CA 26 May 2016
FTTTx STAMP DUTY LAND TAX – sale of property with subsequent Shari’a – compliant sub-sale and lease-back – no SDLT paid pursuant to sections 45(3) and 71A Finance Act 2003- application of section 75A Finance Act 2003- anti-avoidance provision – approach to interpretation of section 75A – identification of ‘V’ and ‘P’ within section 75A(1) … Continue reading Project Blue Ltd v Revenue and Customs: FTTTx 5 Jul 2013
The purchaser of land created a sub-sale and leaseback with bank so as to fund the purchase in a manner which would comply with Islamic finance principles. The Court was now asked whether purchaser or the bank were liable for stamp duty land tax on . .
