Does SDLT arise on the transfer of assets and liabilities between pension schemes where the only consideration is the assumption by the receiving scheme of the obligation to pay pension benefits? HMRC’s answer was originally published in its guidance notes issued on 8 June 2005.
With respect to SDLT, those notes stated:
‘‘No charge to SDLT will arise on any transfers of land from the transferring scheme to the receiving scheme, because there is no agreement to transfer land for consideration in money or money’s worth.’’
Manual, para. SDLTM31750 expands on this statement as follows and is worth reproducing in full.