New queries, issue 4621

Unfinished business

SDLT payable on part purchase of property by daughter of non-dom.

As a non-domiciled resident I intend to gift to my daughter a 60% portion of a house I own in England with a fair market value of £800 000 and sell her the remaining 40% at market value. This sounds complicated but I believe it would be desirable for non-UK tax considerations.

I accept the inheritance tax that would be payable on the value of the 60% portion (£480 000) if I were to die within seven years of making the gift.

My question is on the stamp duty land tax my daughter may have to pay on her purchase of the 40% portion. I see three possibilities:

• No stamp duty land tax is due because she buys a minority interest only.
• Stamp duty land tax is...