ABSTRACT

This chapter describes the main purpose of the connected company's legislation, in relation to Stamp Duty Land Tax (SDLT), was to prevent the setting up of special purpose vehicle companies by arrangement between connected parties, in an attempt to avoid, to mitigate, or to minimise the amount of SDLT properly payable. The meaning of connected persons is as set out in ss 839 and 840 of the Income and Corporation Taxes Act 1988. For the purposes of SDLT, many transactions which are between connected persons, in the general run of events, are exempt from SDLT. Although not mentioned in the Finance Act 2003 (FA 2003), which pre-dates the legislation, the meaning of connected persons, the legislation in this area has been somewhat extended by s 993, etc of the Income Tax Act 2007 and s 179 of the Income Tax Act 2005.