Commentary

B6.736 ATED—contract and conveyance

Business tax
Business tax | Commentary

B6.736 ATED—contract and conveyance

Business tax | Commentary

B6.736 ATED—contract and conveyance

In cases where an SDI is acquired in a transaction involving a contract followed by a conveyance, the rules for ATED broadly mirror equivalent rules for SDLT.

The purchaser under the contract

Where a person ('P') enters into a 'contract' under which1:

  1.  

    (a)     P is to acquire a 'relevant chargeable interest', and

  2.  

    (b)     the acquisition is to be completed by a 'conveyance',

P is not regarded as acquiring any chargeable interest by reason of entering into the contract.

For these purposes2:

  1.  

    (i)     references to completion are to the completion of the acquisition proposed, whether or not between the

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