Q&As

Where, on the surrender of a lease, the tenant pays a reverse premium in excess of £40,000 to the landlord, would the transaction be notifiable to HMRC, notwithstanding the fact that the £40,000 would not be ‘chargeable consideration’ for stamp duty land tax purposes pursuant to paragraph 18 of Schedule 17A to the Finance Act 2003?

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Produced in partnership with Sean Randall of Blick Rothenberg
Published on LexisPSL on 09/05/2019

The following Tax Q&A produced in partnership with Sean Randall of Blick Rothenberg provides comprehensive and up to date legal information covering:

  • Where, on the surrender of a lease, the tenant pays a reverse premium in excess of £40,000 to the landlord, would the transaction be notifiable to HMRC, notwithstanding the fact that the £40,000 would not be ‘chargeable consideration’ for stamp duty land tax purposes pursuant to paragraph 18 of Schedule 17A to the Finance Act 2003?

Where, on the surrender of a lease, the tenant pays a reverse premium in excess of £40,000 to the landlord, would the transaction be notifiable to HMRC, notwithstanding the fact that the £40,000 would not be ‘chargeable consideration’ for stamp duty land tax purposes pursuant to paragraph 18 of Schedule 17A to the Finance Act 2003?

Section 77 of the Finance Act 2003 (FA 2003) (notifiable transactions) determines when a land transaction is notifiable for stamp duty land tax (SDLT) purposes. FA 2003, s 77(1)(b) applies where a lease is surrendered. This is because the subject matter of the transaction is not a ‘major interest’ in land

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