[2012] UKUT 399 (TCC).

Upper Tribunal (Tax and Chancery Chamber).

[The appeal against this decision is reported at [2013] BTC 661.]

Henderson J.

Decision released 5 November 2012.

Stamp duty land tax (SDLT) – Land transaction – Sub-sale – Acquisition by partnership – Acquisition structured to mitigate SDLT charge – Transfer to company and then to partnership of which company was partner – Deemed ‘secondary contract’ – Whether partnership provisions reducing chargeable consideration to nil – Finance Act 2003, s. 44, 45, Sch. 15, para. 10.

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