SDLTM20280 | Freeports and Investment Zones relief – 100% relief

All the consideration for a land transaction qualifies for relief if 90% or more of the consideration is attributable to “qualifying land” (para 5).

Consideration is to be attributed to qualifying land on a just and reasonable basis (para 7(1)).

For example, a purchaser acquires 25 acres of land for £2,500,000.

20 of the acres are situated inside the designated special tax site and are intended for use in a qualifying manner – meaning that these 20 acres count as qualifying land. The other 5 acres are situated elsewhere outside the special tax site.

The 20 acres of qualifying land is however valued on a just and reasonable basis at £2,375,000 (95% of the consideration for the purchase).

Relief will be available for the whole £2,500,000 paid because 90% or more of the consideration is attributable to qualifying land.