SDLTM20290 - Freeports and Investment Zones relief – no relief

There is no relief given where the proportion of chargeable consideration for a transaction that is attributable to “qualifying land” is less than 10% (para 7(4)).

For example, a purchaser acquires 100 acres of land inside a special tax site for £7,500,000.

Although the land is inside a special tax site, all but 3 acres are outside the designated special tax site.

Of the 3 acres inside the special tax site, all are intended for use in a qualifying manner and therefore count as qualifying land. These 3 acres of qualifying land are valued at £500,000 (6.7% of the consideration for the purchase).

No relief will be available for the purchase because the chargeable consideration attributable to qualifying land is less than 10% of the chargeable consideration for the purchase as a whole.