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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