[2018] UKFTT 0233 (TC)

Judge John Brooks

Decision released 23 April 2018

Stamp duty land tax (SDLT) – Avoidance scheme – Purchase of property by unlimited company – Reduction in capital and dividend in specie of the property – Whether consideration for shares is consideration given indirectly for purchase of property (FA 2003, s. 45(3)(b)(i)) – Yes – Whether FA 2003, s. 75A engaged – Yes.

  The First-tier Tribunal (FTT) decided that where transactions are preordained money contributed to a company as a subscription for shares was also consideration given indirectly for the purchase of a property for the purposes of FA 2003, s. 45(3)(b)(i).

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