- Share subscription amounts were consideration for SDLT purposes (Brown and Brown v HMRC)
- Why it matters
- Case details
Tax analysis: In Brown and Brown v HMRC  UKFTT 208 (TC), the First-tier Tax Tribunal (FTT) held that the old sub-sale rules formerly contained in section 45 of the Finance Act 2003 (FA 2003) applied to an acquisition of a property by a company which, on the same day as the acquisition, reduced its share capital and distributed the property in specie to its shareholders. The consideration for the acquisition by the shareholders under FA 2003, s 45 was the amount subscribed for shares in the company.
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