The appellant company was held not to be liable to stamp duty land tax on its acquisition of the former Chelsea barracks that involved finance arrangements which were compliant with Shari’a law.
The appellant company (PBL) completed its acquisition of the former Chelsea Barracks on 31 January 2008. PBL agreed to purchase the site from the Ministry of Defence (MoD) for £959 million, but decided to obtain finance for the acquisition and development of the site in a way which was compliant with Shari'a law.
It did this by contracting to sell the site to a Qatari bank (MAR), for approximately £1.25 billion. This sum was made up of the £959 million required to complete the purchase from the MoD, plus additional amounts to cover stamp duty land tax (SDLT) and future development costs. As part of the arrangements, the contract with MAR was completed on 31 January 2008 contemporaneously with the completion
