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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.
Will the purchase of part of the building by each of the SIPPs be considered a linked transaction for stamp duty land tax purposes.
Query 19 179– Self.
Reply by Mad For It
Clearly the purchase of the commercial property will be a land transaction. The plan is to split the title and acquire parts of the building separately. The difficulty starts here. The title would need to be split into two discrete self-contained titles. Great attention would...
