In Project Blue Ltd v HMRC [2020] UKFTT 475 (TC) (24 November 2020) the First-tier Tribunal (FTT) held that Project Blue Ltd (PBL) was entitled to a refund of overpaid SDLT as part of the consideration for its acquisition was contingent within FA 2003 s 51 and was never paid.
In 2008 PBL acquired a property from the Ministry of Defence for £959m. PBL obtained financing for its acquisition in a way that was compliant with Shari’a law. It entered into an agreement with a lender MAR for £1.25bn under which it sold the freehold of the property to MAR and MAR granted a lease back to PBL. The £1.25bn figure was to finance the property and to cover certain other expenses. It was payable in six tranches provided certain conditions were satisfied. PBL had to serve a price notice on MAR...
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In Project Blue Ltd v HMRC [2020] UKFTT 475 (TC) (24 November 2020) the First-tier Tribunal (FTT) held that Project Blue Ltd (PBL) was entitled to a refund of overpaid SDLT as part of the consideration for its acquisition was contingent within FA 2003 s 51 and was never paid.
In 2008 PBL acquired a property from the Ministry of Defence for £959m. PBL obtained financing for its acquisition in a way that was compliant with Shari’a law. It entered into an agreement with a lender MAR for £1.25bn under which it sold the freehold of the property to MAR and MAR granted a lease back to PBL. The £1.25bn figure was to finance the property and to cover certain other expenses. It was payable in six tranches provided certain conditions were satisfied. PBL had to serve a price notice on MAR...
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.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")