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In October 2006 B entered into a contract to acquire the leasehold interest in a property from A for £65.1 million.
On 29 November the taxpayer partnership C was formed in which B was a partner and had a 98% interest in its income.
On 30 November 2006 C entered into a contract to acquire the lease from B for £65.1 million. At a single completion meeting forms of transfer were executed from A to B and then from B to C.
In brief the taxpayer claimed that the effect of the rules in FA 2003 s 45 was that the transfer from A to B is ignored and stamp duty land tax is payable only on C’s acquisition.
The consideration for that acquisition is treated as...
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