SDLT – Transfer of property to a pension fund

Property Tax, Stamp Duty Land Tax

A commercial property had been acquired in January 2012 by Mr and Mrs P.  The purchase was financed by a loan from ABC Limited, a company in which Mr and Mrs P owned 100% of the shares.  By December 2012 the property had a market value of around £500,00 and Mr and Mrs P had been advised that the property be transferred into their pension fund.

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EIS – Personal training gym startup

Business Tax

The client was a personal trainer who wanted to raise money to set up a gym in Central London by issuing shares qualifying for relief under the Enterprise Investment Scheme (EIS). The shares were to be issued by New Co. which would own and run the gym.  The business model was slightly unusual in that the members of the new gym were to be personal trainers, who would pay a monthly fee to New Co. in order to use the gym facilities with their clients who did not become members.

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SDLT – Rate of tax?

Property Tax, Stamp Duty Land Tax

A company was buying a development site with planning permission to construct eight houses for just over £2 million.  The site was being sold by a single vendor and was made up of one existing house and its garden plus three abutting back gardens.

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VAT – Supplies of dental nurses

Value Added Tax

The client company was a small agency which supplied dental nurses, primarily on a temporary basis, to various dental practices, hospitals and care trusts.  The company had not been charging VAT on the supplies it made.

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SDLT – UK land held in a JPUT

Property Tax, Stamp Duty Land Tax

A Jersey Property Unit Trust (‘JPUT’) owned an industrial site in the UK.  JPUT had received an offer for part of the site and the purchasers wanted to minimise SDLT on the acquisition. Advice was sought on whether it was possible to achieve this by JPUT issuing additional units to the existing unit holders in proportion to their existing holdings.

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VAT – Lease service charge provisions

Property Tax, Value Added Tax

VAT advice was sought on the effect for a tenant of the service charge provisions in a lease of a commercial unit in a building which consisted of two commercial units and eight flats, all owned by the same lessor.  Each lease also carried the right to use a designated car park space.

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SDLT – Linked transactions

Property Tax, Stamp Duty Land Tax

In December 2006 the parents of RB bought a flat for £400,000.  The flat was acquired as joint tenants by RB, his father and his mother. The purchase price was provided by RB’s parents and SDLT was paid on that figure.  At the time of acquisition it was agreed that RB would pay his parents £133,333.33 (one third of the total purchase price) for his share.

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VAT – Sponsorship of charitable activities

Value Added Tax

A registered charity had drafted a proposal under which a major UK corporate would provide the funds to enable it to give grants to 500 individuals to create and develop social and community enterprises.  The sponsor’s employees would be given the opportunity to mentor the participants, and there would be branding and marketing opportunities.

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