Can sub-sales be split into oparts for SDLT?

Home Forums Patrick Cannon Can sub-sales be split into oparts for SDLT?

This topic contains 1 reply, has 1 voice, and was last updated by Can sub-sales be split into oparts for SDLT? by Patrick Cannon 1 Patrick 22nd May 2009 at 9:13 am.

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    Can sub-sales be split into oparts for SDLT? by Patrick Cannon 2
    E J Coley

    A is selling 7.4 acres split into 2.4 acres to X and 5 acres to X’s pension fund (not connected). X is then selling their 2.4 acres for the same price that they bought it from A, on the same day, but the 2.4 acres will be split between Y and Y’s pension fund (again not connected).

    Our intention is to rely on s.45(3) FA 2003 with substantial performance and completion of the A to X contract postponed until substantial performance and completion of the X to Y contract happens.

    Does the split between Y and Y’s pension fund make any difference in relation to sub-sale relief and cause SDLT to be payable on the A to X contract?

    #369 Reply
    Can sub-sales be split into oparts for SDLT? by Patrick Cannon 3
    Patrick

    No it should not matter.

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