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An entity has requested clarification on whether the transfer of its position in a loan agreement and the rectification of an error in the original deed are subject to tax. The DGT has ruled that the assignment of the loan is subject to the variable rate of Stamp Duty (AJD), whereas the rectification is not subject to the tax as it lacks economic substance.
This ruling clarifies the tax treatment for credit assignments, confirming they trigger the variable component of Stamp Duty, while ensuring that purely corrective administrative actions do not incur unnecessary tax liabilities.
The tax team reviews your specific situation.
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