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My client wishes to incorporate her business and we will seek relief under TCGA 1992, s 162. I have seen some texts that suggest that no stamp duty is payable on the issue of the shares, but others suggest that shares issued for a consideration (in my client's case, the assets of her business) attract a liability of 0.5% of the value of the assets (including the goodwill).
My client wishes to incorporate her business and we will seek relief under TCGA 1992 s 162. I have seen some texts that suggest that no stamp duty is payable on the issue of the shares but others suggest that shares issued for a consideration (in my client's case the assets of her business) attract a liability of 0.5% of the value of the assets (including the goodwill).
The business assets include a property on which I believe 1% stamp duty land tax liability will also be payable (the building is worth £200 000). In other words the company has to pay SDLT and my client will be liable for stamp duty on the same transaction.
If we did instead go down the holdover relief route would both stamp duty and SDLT be avoidable?
Query T16 823 – Nun.
Reply by Grover:
TCGA 1992 s...
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