Sean Randall#3726

Sean Randall

Sean is a partner at Blick Rothenberg. For five years, he was head of stamp taxes at KPMG UK, finalist in the 2016 Taxation Awards for Best Big Four Tax Group. He has almost 20 years' experience advising, amongst others, developers, investors, occupiers, funds and banks on stamp taxes in connection with real estate transactions, group reorganisations, corporate reconstructions, demergers and placings. He is a barrister by training, a Fellow of the Chartered Institute of Taxation and council member of the Stamp Taxes Practitioners Group. Since 2007 he has been the editor of Sergeant & Sims on Stamp Taxes arguably the most comprehensive, up-to-date and authoritative guide to UK stamp taxes available. He was the Tax Writer of the Year in the 2017 Taxation Awards having ''demonstrated real in-depth expertise in analysing complex legislation'. He has contributed to the development of government policy, tax authority practice and statutes on stamp taxes, and is regularly consulted by tax authorities and government departments. He speaks and writes regularly on UK stamp taxes.
Contributed to

50

If a purchaser owns a property in a company name, and is now looking to acquire a property in their
If a purchaser owns a property in a company name, and is now looking to acquire a property in their
Q&A

This Q&A considers whether the higher 3% rates of SDLT apply where a purchaser owns a property in a company name, and acquires a property in their individual name.

If a transaction under a single contract entails the sale of a property which comprises two titles of
If a transaction under a single contract entails the sale of a property which comprises two titles of
Q&A

This Q&A considers whether a transaction under a single contract is two transactions for SDLT purposes where one title is being sold by joint vendors and one is being sold by one vendor.

If my application for deferral of stamp duty land tax (SDLT) has not been processed by HMRC by the time I
If my application for deferral of stamp duty land tax (SDLT) has not been processed by HMRC by the time I
Q&A

This Q&A looks at the basis on which to submit a stamp duty land tax (SDLT) return when an application to defer SDLT has not been processed by HMRC by the time the SDLT return needs to be filed.

If within the period of three years from the date of acquiring a new main residence, the former main
If within the period of three years from the date of acquiring a new main residence, the former main
Q&A

This Q&A considers whether a purchaser can reclaim the higher 3% rates of SDLT when it transfers the former main residence to a company owned 100% by the purchaser within three years of acquiring a new main residence.

If, on completing the renewal of a stamp duty land tax lease, the parties agree a new, higher rent is
If, on completing the renewal of a stamp duty land tax lease, the parties agree a new, higher rent is
Q&A

This Q&A considers the treatment of increased rent on the renewal of a lease for stamp duty land tax purposes.

In what circumstances would the grant of an option and the subsequent exercise of it not be linked
In what circumstances would the grant of an option and the subsequent exercise of it not be linked
Q&A

This Q&A considers in what circumstances would the grant of an option and the subsequent exercise of it would not be linked transactions for SDLT purposes.

Is a bank required to pay stamp duty land tax and submit a return when it sells a property following
Is a bank required to pay stamp duty land tax and submit a return when it sells a property following
Q&A

This Q&A considers whether a bank is required to pay stamp duty land tax and submit a return when it sells a property following repossession. This Q&A is produced in partnership with Sean Randall of Blick Rothenberg.

Is a claim for overpayment relief appropriate to rectify a previous failure to claim multiple dwellings
Is a claim for overpayment relief appropriate to rectify a previous failure to claim multiple dwellings
Q&A

This Q&A considers whether a claim for overpayment relief is appropriate to rectify a previous failure to claim multiple dwellings relief (MDR).

Is a transfer of equity from one spouse to both spouses exempt from stamp duty land tax (SDLT) where the
Is a transfer of equity from one spouse to both spouses exempt from stamp duty land tax (SDLT) where the
Q&A

This Q&A considers whether a transfer of equity from one spouse to both spouses is exempt from stamp duty land tax where the transferee spouse assumes debt. This Q&A also considers whether the higher 3% rates might apply.

Is stamp duty payable on the sale of shares as a result of a divorce settlement?
Is stamp duty payable on the sale of shares as a result of a divorce settlement?
Q&A

This Q&A considers the stamp duty exemption for transfers of shares as a result of a divorce settlement.

Is the use of a driveway as a farm road for commercial and agricultural vehicles sufficient to allow a
Is the use of a driveway as a farm road for commercial and agricultural vehicles sufficient to allow a
Q&A

This Q&A considers SDLT rates for a dwelling that has a driveway that is used for both commercial and agricultural vehicles.

Is there any potential stamp duty land tax payable as a result of entering into a deed of
Is there any potential stamp duty land tax payable as a result of entering into a deed of
Q&A

This Q&A considers the stamp duty land tax treatment of varying or releasing a restrictive covenant over land.

It is understood that a mortgagee may transfer a loan it has and the mortgagee's estate in the legal
It is understood that a mortgagee may transfer a loan it has and the mortgagee's estate in the legal
Q&A

This Q&A discusses whether SDLT will be payable when a mortgagee transfers the loan and at the same time transfers as mortgagee in possession its right to its estate in the security by transferring the actual security. This Q&A was produced in partnership with Sean Randall of Blick Rothenberg.

Land is subject to an existing 50-year overage deed and ten years have passed. The seller did not apply
Land is subject to an existing 50-year overage deed and ten years have passed. The seller did not apply
Q&A

This Q&A considers when an application to defer stamp duty land tax in respect of an overage arrangement can be made and whether it can be made ten years after the agreement was made.

On the purchase of two adjoining properties, one containing a residential flat and commercial unit (let
On the purchase of two adjoining properties, one containing a residential flat and commercial unit (let
Q&A

This Q&A considers the stamp duty land tax (SDLT) position when a person acquires two properties, both of which contain residential property and one that contains commercial property.

Party A has the benefit of four options to purchase eight-rear gardens in England and a fifth option to
Party A has the benefit of four options to purchase eight-rear gardens in England and a fifth option to
Q&A

This Q&A considers whether a transfer of land is treated as commercial or residential for SDLT purposes where a party exercises options to acquire rear gardens and a private access road and then sub-sells to another party.

What are the SDLT obligations when a lease, which was not originally notifiable for SDLT purposes, is
What are the SDLT obligations when a lease, which was not originally notifiable for SDLT purposes, is
Q&A

This Q&A considers a tenant's SDLT obligations in respect of the holding over of a non-notifiable lease .

When a minor is purchasing a property through a bare trust, in what circumstances are the minor’s parents
When a minor is purchasing a property through a bare trust, in what circumstances are the minor’s parents
Q&A

This Q&A considers when the higher 3% rates of stamp duty land tax may apply where a minor acquires a residential dwelling.

Where a landlord and tenant are connected and section 53 of the Finance Act 2003 applies, will a
Where a landlord and tenant are connected and section 53 of the Finance Act 2003 applies, will a
Q&A

This Q&A considers whether a variation of a lease to reduce its term will be subject to stamp duty land tax where the landlord and tenant are connected and section 53 of the Finance Act 2003 applies.

Where a landlord has agreed a reduced concessionary rent in a side letter, is stamp duty land tax payable
Where a landlord has agreed a reduced concessionary rent in a side letter, is stamp duty land tax payable
Q&A

This Q&A considers the meaning of rent for the purposes of calculating stamp duty land tax.

Practice Area

Panel

  • Q&A Panel

Qualified Year

  • 2000

Membership

  • CIOT

Education

  • LLB (Hons)
  • CTA (Fellow)

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