Commentary

B6.750 ATED—property developers: exchange of dwellings

Business tax
Business tax | Commentary

B6.750 ATED—property developers: exchange of dwellings

Business tax | Commentary

B6.750 ATED—property developers: exchange of dwellings

Property developers may also be able to claim relief from ATED when they acquire a residential property as part of a 'qualifying exchange' in return for the transfer of a newly constructed (and not previously occupied) residential property to the vendor.

A day in a chargeable period is a relievable day in relation to an SDI for the purposes of this relief if1:

  1.  

    (a)     a person ('the property developer') is on that day entitled to an SDI ('the returned interest') that was acquired (by the 'relevant person' (see below)) in the course of a property development trade

  2.  

    (b)     that acquisition ('the reverse acquisition') was 'part of a qualifying exchange'

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