Project Blue: A Stamp Duty Land Tax Case That Made Headlines


In July 2013, the Stamp Duty Land Tax (SDLT) case of Project Blue Ltd v. HM Revenue & Customs, concerning the high-profile development of Chelsea Barracks, was the first real test of the SDLT’s broad anti-avoidance rule (Section 75A of the Finance Act 2003). This advisory considers why Project Blue has attracted mass media comment and why the real estate sector should take note of it.

The Transaction -

The transaction (including the SDLT scheme) can be summarised as follows:

- In 2007, Project Blue Ltd (P), a Guernsey company (then a joint venture between Qatari Diar and CPC Group), agreed to purchase the freehold of Chelsea Barracks from the Ministry of Defence (MoD) for £959 million.

- In January 2008, P entered into a sale and leaseback agreement with a Qatari financial institution specialising in Shariacompliant finance (“Bank”), together with put and call options under which P could repurchase the freehold at the expiry of a 999-year “finance period.”

- The MoD transferred the freehold to P, P transferred the freehold to Bank and Bank leased the property back to P.

Please see full advisory below for more information.

LOADING PDF: If there are any problems, click here to download the file.

Written by:

Published In:


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Katten Muchin Rosenman LLP | Attorney Advertising

Don't miss a thing! Build a custom news brief:

Read fresh new writing on compliance, cybersecurity, Dodd-Frank, whistleblowers, social media, hiring & firing, patent reform, the NLRB, Obamacare, the SEC…

…or whatever matters the most to you. Follow authors, firms, and topics on JD Supra.

Create your news brief now - it's free and easy »

All the intelligence you need, in one easy email:

Great! Your first step to building an email digest of JD Supra authors and topics. Log in with LinkedIn so we can start sending your digest...

Sign up for your custom alerts now, using LinkedIn ›

* With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name.