Q&As

Will the purchase of a property be subject to higher SDLT rates if individual purchasers have recently transferred their existing property for value to a Special Purpose Vehicle (SPV) in which they have a controlling interest?

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Produced in partnership with Graham Callard of 9 Stone Buildings
Published on: 11 May 2017
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The legislation in respect of the 3% SDLT higher rates for additional dwellings is contained in Schedule 4ZA to the Finance Act 2003 (FA 2003).

For an individual purchaser, FA 2003, Sch 4ZA, Pt 2, para 3 provides that if the property is a major interest in a single dwelling then the higher rates will apply if conditions A to D in FA 2003, Sch 4ZA, Pt 2, para 3(2) to FA 2003, Sch 4ZA, Pt 2, para 3(5) are present. A major interest in a single dwelling is a higher rates transaction for the purposes of FA 2003, Sch

Graham Callard
Graham Callard

Barrister, 9 Stone Buildings

Graham is a very experienced tax lawyer with over 30 years of experience in firstly the accountancy profession, then the insurance industry. Graham has spent 10 years as an employed barrister providing tax advice for clients of firms of solicitors, and is now practising at the independent bar from 9 Stone Buildings, Lincoln's Inn. As a tax specialist, Graham has principally focussed on the following taxes: income tax, corporation tax, capital gains tax, VAT, inheritance tax, national insurance, stamp duty, stamp duty land tax and more recently ATED.

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Jurisdiction(s):
United Kingdom
Related legal acts:
Key definition:
Special purpose vehicle definition
What does Special purpose vehicle mean?

A legal structure sometimes also used in contingent asset funding strategies under which both the sponsor and the fund achieve a specific objective, eg the employer places assets into an SPV which are loaned back to the employer on specified terms, the returns being shared between the fund and the sponsor.

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