SDLT – Group relief Q&A

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The client is non-resident (he lives in Ireland).  He owns 100% of a UK company(‘UK Co.’) which in turn owns various UK properties which are all mortgaged.  The client has been advised by his Irish lawyer to exchange his shares in UK Co. for shares in a new Luxembourg company (‘Lux Co.’).

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SDLT – Two LLP scenarios

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Scenario One

A Limited Liability Partnership owns a portfolio of UK properties which are let.  Two unconnected individuals are the members of the LLP.  A company (‘Co’) connected with one of the individuals has lent the LLP £500,000 at some time in the past.

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Tax treatment of capital contributions between parent and subsidiary

A US parent company (US Co.) owned the entire issued share capital in a UK company (UK Co.). UK Co. owned the entire issued share capital in three UK companies, MG, GBS and CPP. US Co. intended to make a capital contribution to its UK subsidiary, UK Co.  UK Co. would then use that contribution to make capital contributions to GBS and CPP.  The purpose of the capital contribution to UK Co. was to enable it to provide its subsidiaries GBS and CPP with funds to acquire capital assets.

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VAT – When is a book not a book?

A small commercial law firm referred one of their clients for help in establishing the VAT liability of their product. E-Books produce ‘photobooks’ and became concerned when they discovered that one of their competitors had been assessed by HMRC on the basis that their product was subject to VAT at the standard rate.

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UK – US corporate joint venture – Choice of vehicle

UK Co. operated a share registration business in the UK. US Bank had a similar business in the US. UK Co. and US Bank intended to form a JV to which each would contribute its share registration business. The JV vehicle was to be either a UK company registered in England and Wales or a Delaware Limited Liability Company (LLC).

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