Blick Rothenberg

This Practice Note sets out the key UK tax considerations for an overseas purchaser acquiring a UK business by way of asset sale or share sale, often referred to as an inbound transaction. It considers the potential tax costs of the acquisition, the tax considerations when returning profits overseas, the tax efficiency of the target business and how such a cross-border transaction might be structured so as to mitigate UK tax costs and maximise UK tax efficiency. This Practice Note is produced in partnership with Tim Shaw of Blick Rothenberg Limited.

This Q&A considers whether the higher 3% rate of SDLT applies to a purchase of a mixed use property.

This Q&A considers if certificates on stock transfer forms can be signed and dated a number of years after the share transfers took place.

This Q&A considers SDLT and CGT issues that would arise where a company holds a share of a property on trust.

This Q&A considers the SDLT treatment of an increase in rent on an assignment of a pre-2003 lease

This Q&A considers whether both the tenant seller and buyer will be liable to pay SDLT when the tenant of a shared ownership lease proceeds with final staircasing and sells the property.

This Q&A considers whether a rebate of SDLT is available to executors, where the deceased person bought a replacement main residence and paid the higher rates, but died before they could move into the house.

This Q&A considers whether a non-profit organisation (a company limited by guarantee) that is not a registered charity can claim relief from SDLT.

This Q&A looks at whether the higher 3% rates of SDLT can be reclaimed when the additional home is sold within three years of its purchase.

This Q&A considers the application of MDR on the acquisition of a property that includes a house with a granny annex in the garden.

This Q&A considers the case law regarding the definition of ‘annexe’ with regards to multiple dwellings relief for SDLT.

This Q&A looks at the stamp duty land tax (SDLT) consequences of an amendment to an overage provision where the overage was originally granted before SDLT was introduced.

This Q&A considers whether UK stamp duty or SDRT apply to the grant of an option (that is governed by English law) to acquire shares that are issued by a non-UK company.

This Q&A considers the calculation for the 30 day limit to file an SDLT return.

This Q&A considers the SDLT treatment of a deemed surrender and re-grant of a lease over commercial premises and a reversionary lease over commercial premises. This Q&A was produced in partnership with Sean Randall of Blick Rothenberg.

This Q&A considers how SDLT is calculated when the buyer has entered a raffle to win a house.

This Q&A discusses how SDLT is charged in regard to a land swap between parties and the guidance available on such a transaction.

This Q&A considers the situation when a buyer purchases two properties at an auction from the same seller and whether the two purchases will be linked transactions for SDLT purposes.

This Q&A looks at whether an increase made in year four of the term of a lease to the rent from year six constitutes a grant of a new lease for stamp duty land tax purposes.

This Q&A looks at the SDLT position on a variation of a lease that amends the rent provisions