How are SIPPs treated for SDLT?

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    How are SIPPs treated for SDLT? by Patrick Cannon 2Andrew Campbell
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    It seems that a SIPP is a settlement as opposed to a bare trust under Sch.16, so a property acquiistion by a SIPP is an acquisition by the trustees rather the person(s) entitled to pension benefits.

    Does the making of contributions in cash or kind, by such a person, turn that person into a settlor, for the purposes of S839 ICTA ’88? S620(1) ITTOIA 2005 seems to say yes to thatr.

    If so and if the person is one of the trustees of the SIPP, the person and the SIPP trustees are connected for S108 FA 2003 purposes.

    But presumably not connected if neither the person nor anyone connected with him/her is appointed a a SIPP trustee.

    If that’s right, presumably it will make sense for SIPP “owners” to avoid becoming a trustee of any property assets acquired by the SIPP.

    Or am I completely mising apoint?

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