New queries, issue 4648

Linked transaction

Is a building purchase by two SIPPs a ‘linked transaction’ for SDLT?

I have a client who wishes to purchase a commercial property for about £750 000. The plan is to split the title and acquire part of the building in both his and his wife’s self-invested personal pensions (SIPPs) roughly in the proportion of 60:40.

The trustees of both SIPPs will be a ‘well-renowned’ SIPP trustee company. The sole tenant of the property will be my client’s trading company.

My question for Taxation readers is whether the purchase of part of the building by each of the SIPPs would be considered a ‘linked transaction’ for stamp duty land tax purposes.

Query 19 179– Self.

Blindsided

Submitting a return without knowledge of information advised by third party.

I have acted for many years for one of my largest clients whose tax return...