Q&As

If a property is purchased by an SPV that will hold the property on bare trust for a company (non-charity) and a charity, can charities relief from SDLT be claimed on the purchase?

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Published on LexisPSL on 11/03/2021

The following Tax Q&A provides comprehensive and up to date legal information covering:

  • If a property is purchased by an SPV that will hold the property on bare trust for a company (non-charity) and a charity, can charities relief from SDLT be claimed on the purchase?

If a property is purchased by an SPV that will hold the property on bare trust for a company (non-charity) and a charity, can charities relief from SDLT be claimed on the purchase?

We have assumed that the land is in England or Northern Ireland.

As further explained in Practice Note: SDLT—general reliefs and exemptions, relief from stamp duty land tax (SDLT) is available on the acquisition of an interest in land by a charity or a charitable trust subject to various conditions. A land transaction is exempt from SDLT if the purchaser is a charity or charitable trust (as defined) and the following conditions are satisfied:

  1. the purchaser must hold the property for 'qualifying charitable purposes', and

  2. the transaction must not have been entered into for the purposes

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