Leasehold interests

Our clients A B and C formed a limited company to facilitate a leasehold enfranchisement of their three flats in a property.

The three clients each loaned the company £1 million to enable it to acquire the freehold interest.

Immediately after the acquisition of the freehold the company granted three 999-year leases to A B and C.

The leases do not mention any premium and refer to consideration of only ‘the respective rents and the covenants hereinafter reserved and contained’. The annual rent is a peppercorn (if demanded).

I am a little confused as to the implications of these transactions and should be grateful if Taxation readers could please clarify the following points.

1. Whether there are four stamp duty occasions here or whether there is some statutory or concessionary relief.
2. Whether there is any possibility that the company could...