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Patrick Cannon examines the recently announced proposals for a full SDLT charge on the sale of SPVs owning residential property
In the PBR on 9 October 2007 HM Treasury signalled that it wished to examine the possibility of imposing an SDLT charge on the transfer of an interest in a special purpose vehicle (SPVs) owning land. In the April 2002 Condoc on SDLT Ruth Kelly (the then Economic Secretary) had described the use of property owning SPVs as 'a major threat to the Exchequer' and promised that a special 'land-rich' SPV charge would be included within the new SDLT when it replaced stamp duty (on 1 December 2003). In the event this charge was quietly dropped and the failure of Ruth Kelly to follow through on something that she thought was 'a major threat to the...

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