Practice guide: how to avoid SDLT bear traps

The SDLT rules contain a number of traps. The rules on leases give rise to particular issues in relation to nominees and to certain first assignments of leases. The value of construction works may count as chargeable consideration, and the legislation on this is opaque. Repayments of loans by partnerships may trigger SDLT. Multi-step transactions may be re-characterised. Group relief may be denied where there is a main purpose of tax avoidance. Group relief may be clawed back on a change in control.