In Ladywalk LLP v HMRC [2020] UKFTT 207 (TC) (5 May) the FTT held that held that an acquisition of a property was effected pursuant to a June 2014 contract which had not been varied and was therefore protected by transitional provisions and the old slab system of calculating SDLT applied to the acquisition.
The June 2014 contract was between two individuals (A and B) and concerned the acquisition of two properties. It was brief and recorded some key terms including the price and the fact that they buyer might be B one of his children or someone else they nominated; it also provided that the agreement was binding on both parties and was to form the basis of detailed sale/purchase agreements
In June 2015 A and B signed a further agreement under which set a long stop date for completion. Ladywalk LLP (an LLP whose ultimate beneficial...