New SDLT sub-sale sale relief

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By Niall Murphy

In an earlier article, Shoosmiths outlined the introduction of the new sub-sale relief rules. These have now been enacted in the Finance Act 2013.

Broadly, under the new provisions, the intermediate purchaser in a transaction has to submit a claim for the relief. Otherwise, the intermediate purchaser will have to pay SDLT on the consideration payable under its contract as well as the ultimate purchaser paying SDLT, usually on substantially the same consideration.

Despite representations having been made, there appears to be a technical problem with the new SDLT sub-sale rules (relating to sub-sale transactions), which could have potentially significant commercial implications…

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