A UK situated holiday rental property is owned by an offshore company. SDLT was paid on the original purchase by the offshore company.
The director shareholders want to raise a mortgage on the property, and have a mortgage offer from a UK building society, provided the property is UK owned.
Can the transfer of ownership to the UK be achieved without incurring SDLTagain?
From a practical (non tax) point of view. there wouldn't be a problem with the property being transferred to one of the offshore company shareholders, who is non UK domiciled but has a UK passport.
Alternatively could it be transferred to a UK company?
Final point is the original SDLT was on a much lower value than the value now, as the property has undergone significant development.