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9th January 2012 at 11:51 am
#624
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This issue also arises in some very ordinary situations, for example:
Husband owns property entirely; Husband forms LLP with wife as equal partners and transfers property into LLP; No SDLT charge on transfer under para 10; Wife leaves LLP and her interest transfers to Husband; Husband charged to SDLT on half of market value of property under para 14; Husband then decides to hold the property in his own name and wind up the LLP; SDLT charge on market value of property under 18.
Overall SDLT is paid on 150% of market value of property!!