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HMRC internal manual

Stamp Duty Land Tax Manual

Application: Transactions involving pension funds

Example 2

Pension fund A transfers all its assets to Pension fund B, these assets include UK land and property. There is a £500,000 mortgage secured on these properties and the transfer is subject to this charge plus a sum of £2.3m. The transfer of this land is a land transaction: the chargeable consideration will be a just and reasonable apportionment of the £2.3m (i.e. the amount that relates to the UK land and property) plus the £500,000 debt. The obligation to provide benefits to A’s pension holders is not chargeable consideration.

An SDLT1 should be lodged showing the total of the apportioned consideration plus the £500,000 debt assumed.