As to paragraph 2(4A)(a) Schedule 7 FA 2003, the Tribunal has found that the transfer of the Lease to the Appellant was effected for bona fide commercial reasons, and this was not disputed by HMRC. Purpose does not mean "end result in fact", as opposed to the end result that the arrangements were designed to achieve. Take a seat and relax with a drink! Room w/ Wardrobe (London Fields/Broadway market), Stylish double room with workspace-East london #2, A-cosy-room-in-a-5-bed-house-3-minutes-the-tube. The information displayed about this property comprises a property advertisement. Website. At 181 metres, it is the tallest residential tower in London. The information is provided and maintained by Prime London, Central London. 60 + min. So the mooted tax advantage didn't actually happen. day, and this was a transaction "within the period of three years immediately preceding the effective date of the transaction". * This is the average speed from the provider with the fastest broadband package available on comparethemarket.com at this postcode. The question is whether a purpose is one of the main purposes, not whether it is the most important purpose, and not whether the arrangements would be proceeded with in the absence of any of the other purposes. We've collected top 10 mentioned gelato in Greenbank from other articles such as Day Out With The Kids, the Guardian, yably.co.uk. A purpose can be a "main" purpose, even if it is not as significant a consideration as another main purpose. Read more Tenancy info Added on 09/12/2022 Letting details Let available date: Now Deposit: 9,600 A deposit provides security for a landlord against damage, or unpaid rent by a tenant. main purpose, could have been achieved by far less complicated means. Managing the risks associated with the development is an ongoing process. "Purpose" means the intended effect of the arrangements, not the motive of the taxpayer for wanting to achieve the intended effects. This property advertisement does not constitute property particulars. Where arrangements are complex and/or have been devised by specialists other than the taxpayer, regard may therefore also be had to wider considerations such as why the arrangements took the form that they did, how those who devised them hoped that they would work, and the way that those who devised them presented them to the taxpayer(s). (2) Prior to the transactions that took place on 5 July 2011, there was an agreement by those entering into the transactions that they would do so. A document confirming the energy efficiency rating of the property. The property also comes with valet parking. (10) Rather, the step plan involved a course of action designed to conflict with or defeat the evident intention of Parliament, by removing from tax liability some 170 million of latent profit that would otherwise have been taxable. it is still apparently listed on some sites like airbnb, . (b) the Lease, the premium for which was left outstanding as an intercompany receivable. As of October 2011 the concrete core had reached level 22. It will offer 223 apartments arranged over 52 floors and the st ructure will be topped off with a wind turbine. 23m El rincon Latino . 995 /week. An SPV structure would also introduce opportunity and flexibility around raising finance to fund the development and also in the event the development, at any stage, attracts the appetite of a single investor or developer. It follows from the findings above that the Appellant is chargeable to SDLT on its acquisition of the Lease from B64, based on the market value of the Lease on the effective date of the transaction. If the final words of s 54(4) FA 2003 are read as referring to both valid and invalid group relief claims, the effect in practice is as follows. A final decision was made by the then Deputy Prime Minister John Prescott in 2005 and the tower was approved, against the decision of the planning inspector and despite warnings from Prescott's own advisers that it "could set a precedent for the indiscriminate scattering of very tall buildings across London".[7]. Although not conclusive, it is relevant to note that the parties were aware of s 45, and were not seeking to effect a sub-sale to which s 45 applies. The 50m penthouse is located at the very summit of The Tower. [5] At the base of the tower, water is drawn from the London Aquifer and heat pump technology is used to remove warmth from the water in the winter to heat the apartments. HotTub+FirePit *3Bed/3Bath* Heated Pool, *Reduced* 3BR/3BA w/HotTub+Pool *FREE Park Passes. Website de.wikipedia.org. (4) The consequence of this is as follows. Call. Sports Village - Coolest One Bedroom in St George! When results are available, navigate with the up and down arrow keys or explore by touch or swipe gestures. 80. 27. The building was designed by Broadway Malyan and the main contractor is Brookfield Multiplex Construction Europe Ltd. For s 45 FA 2003 to apply, it is necessary that, as a result of the "assignment, sub-sale or other transaction" referred to in s 45(1)(b), a person other than the original purchaser has acquired a legal right to call for a conveyance. The Tribunal is unable to conclude that the tax benefits ever became more important to the Appellant than the original commercial considerations. (3) However, this prior agreement was not an "assignment, sub-sale or other transaction" for purposes of s 45(1)(b) FA 2003, as this prior agreement did not confer on the Appellant a legal right to call for a conveyance (see paragraph 49 above). The steps included the grant of a 999 year lease of the land to a third company and a subsequent transfer from that third company to the taxpayer. 25m The Garden Party Flower Service . s 54(4)(b) depends on whether or not B64 made a group relief claim in respect of the earlier transaction, not whether B64 was entitled to group relief, and not whether HMRC considered that B64 was entitled to group relief (paragraphs 73- 81 above). However, it follows from the previous paragraph above that a taxpayer in this situation may well be acting with a main purpose of avoiding tax if the chosen way conflicts with or defeats the evident intention of Parliament. Find the widest range of offers for your search to rent st georges wharf vauxhall. The highest swimming pool in the city is located in this apartment. Cabin in the country - quiet and peaceful This cabin is located on 65 acres with plenty of hiking trails and wildlife to observe. The Park Tower 70 spaces. (1) The Form TR1 transferring the Lease in respect of the Tower from B64 to the Appellant cannot be an "assignment, sub-sale or other transaction" for purposes of this provision, as it was executed only later on 5 July 2011, after the acquisition of the Lease by B64 from SGSL had already been completed (see paragraph 48 above). Book unique homes, vacation rentals, and more on Airbnb. A payment made to your local authority in order to pay for local services like schools, libraries, and refuse collection. (11) The fact that ultimately no tax was avoided does not mean that the arrangements cannot have had the purpose of avoiding liability to tax (see paragraph 63 above). 91. 26. By virtue of s 51(4)(b) FA 2003, the Case 3 exception to the deemed market value rule will not apply if a group relief claim was in fact made in respect of a relevant prior transaction (see s 62(3) FA 2003), whether or not the company making that claim was entitled to the group relief claimed. Part 1 Schedule 7 FA 2003 provides for a form of relief from SDLT known as "group relief" (s 62(1) and (2) FA 2003). - One step away from Stepney Green Station. Get the amount of space that is right for you. Paragraph 2(5) Schedule 7 FA 2003 provides that: "arrangements" includes any scheme, agreement or understanding, whether or not legally enforceable; , Deemed market value rule (ss 53 and 54 FA 2003), 36. This lateral apartment comprises of open plan kitchen, and reception room ideal for entertaining, principal . This five-acre, interactive desert garden is Utahs first conservation garden and is dedicated to preserving plant species that require reduced maintenance and water use. 90. Section 45 FA 2003 does not apply to the circumstances of the grant of the Lease by SGSL to B64, followed by the transfer of the Lease from B64 to the Appellant. PwC advised that St George would recognise a trading profit as a result of a transfer pricing adjustment and that B64 would be entitled to an equal and opposite corresponding adjustment in the same year. to . People come from all over to take advantage of its incredible hiking, mountain biking, and rock climbing. Please contact the selling agent or developer directly to obtain any information which may be available under the terms of The Energy Performance of Buildings (Certificates and Inspections) (England and Wales) Regulations 2007 or the Home Report if in relation to a residential property in Scotland. There are 3 ways to get from Egham to St George Wharf Tower by train, taxi or car. The effective date of the transaction except where otherwise provided is the date of completion (s 119(1) FA 2003). 19. Dimensions: 3648 x 5472 px | 30.9 x 46.3 cm | 12.2 x 18.2 inches | 300dpi Date taken: 24 October 2022 Build To Rent Furnishing Solutions. St. George Wharf Tower Lyrics [Verse 1] May pole flies Another diary entry You don't need a century To watch over you Many have died trying to be the hero You don't need a hero In these. In 2000, SGSL sold St George Wharf to St George, but the legal interest was not transferred to St George. Thus, at the time of the transfer of the Lease from B64 to the Appellant, the Lease had been subject to an earlier transaction in which a group relief claim had been made. Recommended option Train Ensure you're up to date with our latest advice on how to avoid fraud or scams when looking for property online. Project Details Address Londres, Royaume-Uni. 64. Speeds can be affected by a range of technical and environmental factors. Tickets can be bought at ticket machines at the pier before travel, but to save time and money touch in and out with your Oyster or contactless card. King Beds * Luxury Kitchen * Pool, Stunning 3 Bedroom Luxury Home with Hot Tub + Pool. PwC advised that the shares should be treated as having been transferred at no gain/no loss and then appropriated to trading stock by the Appellant at market value, thus triggering a gain but one which the Appellant would elect to roll over into the carrying cost of the shares. The hearing of this appeal was held on 14, 15 and 16 March 2022. 14. Cozy St. George Condo Near Zion National Park. 24 hours concierge Property description This exceptional two bedroom apartment of 1,052 sq ft (97.7 sqm) located on a higher floor in the iconic St George Wharf Tower on the River Thames, comes fully furnished and is available to rent through Prime London Residential. Las Palmas - Brand NEW with an AMAZING View! 59. Call. In 1997, SGSL acquired from unconnected third parties the freehold interest in a site in the Nine Elms area of Vauxhall known as St George Wharf ("St George Wharf"). The tower was originally designed as a traditional reinforced concrete (RC) structure, with a saw-toothed floor-plate design creating steps in the facade. Hotels near Fun Station, London on Tripadvisor: Find traveler reviews, 50,022 candid photos, and prices for 2,547 hotels near Fun Station in London, England. The Tribunal finds that at all material times the group of companies wanted to transfer the Tower to the Appellant in order to ring-fence risks and potential liabilities associated with the development, and to provide greater financial flexibility by opening up the prospect of securitized borrowing from a wider group of lenders. 22 2 hours. For s 45 FA 2003 to apply, the "assignment, sub-sale or other transaction" referred to in s 45(1)(b) must entered into before the land transaction referred to in s 45(1)(a) has been completed. St George Wharf, situated within minutes of Victoria and Waterloo stations is in a prime location. At 181 meters tall with 50 storeys, The Tower is the eighth-tallest building in London and the tallest residential building in the United Kingdom. Where it is other transactions within the scheme, agreement or understanding that have the effect of avoiding tax, it is immaterial whether those other transactions are effected before, simultaneously with, or after the specific transaction on which SDLT would be chargeable. St George Wharf Tower, also known as the Vauxhall Tower, is a residential skyscraper in Vauxhall, London, and part of the St George Wharf development. 63. Private en suite bathroom with shower, sink, toilet, towels + breakfast is included every morning! At the time that a land transaction return is filed, it will be a relatively simple matter to determine whether a group relief claim was made in respect of a relevant prior transaction in the previous three years. The property also comes with valet parking. Disclaimer - Property reference 102986004508. 37. Indeed, there may be a pending dispute about whether the earlier group relief claim was validly made, if for instance an HMRC enquiry into that claim is still open, or if an appeal against an HMRC decision following such an enquiry is still in progress. When results are available, navigate with up and down arrow keys or explore by touch or swipe gestures. However, the evidence before the Tribunal is not sufficient to allow the Tribunal to make any assessment of its own of the commercial significance of these matters, and to weigh them against the significance of the tax benefits. Rightmove.co.uk makes no warranty as to the accuracy or completeness of the advertisement or any linked or associated information, and Rightmove has no control over the content. This comprised a partial post-tensioned (PT) solution for levels 3-45, which were of the same basic layout, consisting of post-tensioned overlapping circumferential rings, with reinforcement in the secondary direction. The property is located within a short walk to va The high-specification cladding needed strict deflection control, which would have required excessive levels of back propping to the RC slabs, potentially impacting on follow-on trades. At level 49 post-tensioned ring beams were installed to help support penthouse apartment pools. The amount per month or week you need to pay the landlord. 26m Riverside-London . Oral evidence was given by Mr Stearn, director of the Appellant company and now group finance director. However, it is clear from the wording of paragraph 2(4A) Schedule 7 FA 2003 that "arrangements" for purposes of that provision may have more than one main purpose. If youre visiting during this time, its best to plan your outdoor activities early in the morning or close to dusk, when its cooler. 84. In particular, the exception to the deemed market value rule in s 54(4) FA 2004 (Case 3) does not apply: B64 had made a group relief claim in respect of the grant of the lease to it by SGSL earlier the same. The memorandum concludes by stating that "I await your [Mr Simpkin's] confirmation of the underlying transaction and the optimisation identified by in the context of our recent HMRC discussions". It is charged on the purchaser (s 85(1) FA 2003), who must notify the transaction by way of a land transaction return within (in 2011) 30 days of the effective date of the transaction (s.76(1) FA 2003). 242, St. George, Bristol, City of Bristol, South West England An impressive 1 bedroom apartment situated in The Tower, a 181 meters tall only residential building is available to rent. Apartment. 13. As regards stamp duty land tax ("SDLT"), the land transaction returns (SDLT1) filed by: (1) B64, in respect of the initial entry into the agreement for lease and the grant of the Lease of the Tower by SGSL to B64; and. Before confirming, please ensure that you have thoroughly read and verified the judgment. This agreement for lease entered into by SGSL and B64 was a contract for a land transaction, and this land transaction was completed by the grant of the Lease by SGSL to B64. CCL provided design support and installed its post-tensioning systems within the transfer ring beams. London, The average speed displayed is based on the download speeds of at least 50% of customers at peak time (8pm to 10pm). St George acquired the site [St George Wharf] in 1996/97 and is now beginning the final phase which is a 50 storey tower, comprising some 220 high spec residential units. 79. 1. Spacious 1 Bedroom Condo With Cute Bonus Room. (1) The only potentially applicable exception identified by the parties is Case 3 in s 54(4) FA 2003. Complimentary wireless Internet access keeps you connected, and cable programming is available for your entertainment. 67. By virtue of s 45(3) FA 2003, where that section applies, s 44 applies as if there were a contract for a land transaction (referred to as a "secondary contract") under which the transferee of the assignment, sub-sale or other transaction is the purchaser, and the substantial performance or completion of the original contract at the same time as, and in connection with, the substantial performance or completion of the secondary contract shall be disregarded. In general, it may be said that it is not tax avoidance to accept an offer of freedom from tax which Parliament has deliberately made, but that it is tax avoidance to adopt a course of action designed to conflict with or defeat the evident intention of Parliament by taking advantage of a fiscally attractive option afforded by the tax legislation without incurring the. 1BRM modern w/d hot tub/gym/Perfect Spot! Pursuant to this advice, the Tower was transferred to the Appellant by a series of steps which were all executed on the same day. 38. 47. Citation. (5) There is no reason in principle for treating differently a case where a taxpayer has a mistaken belief that the arrangements will lead to a tax saving that is significantly greater than the SDLT payable, but in fact the arrangements do not result in the avoidance of any tax at all. The effect of such treatment would be to allocate the Appellant's cost of acquiring the shares in B64 to: (i) the fair value of the investment in B64 after the hive up of the Tower and (ii) the fair value of the Tower as stock. The holiday home featur (b) forms part of arrangements of which the main purpose, or one of the main purposes, is the avoidance of liability to tax. Fibre/cable services at the postcode are subject to availability and may differ between properties within a postcode. (7) This was not a case where there were two obvious or standard ways of transferring the Tower from SGSL to the Appellant, and where the Appellant simply chose the way that was least costly in terms of tax. (8) Rather, the PwC step plan was a bespoke plan, devised by professional advisers, for an arrangement that would not only reduce or eliminate the tax costs of transferring the Tower from SGSL to the Appellant, but would in fact confer a very substantial positive financial gain on the Appellant. The tower was originally designed as a traditional reinforced concrete (RC) structure, with a saw-toothed floor-plate design creating steps in the facade. Meaning of "main" (paragraph 2(4A) Schedule 7 FA 2003). (4) It is immaterial that HMRC concluded that the group relief claim made by B64 did not need to be considered because sub-sale relief was available. Amira is a vacation community that sits right in the heart of some of Southern Utahs best biking/walking trails, family entertainment, and more. Where s 53 FA 2003 applies, it has pursuant to s 53(1A) the following effect. Stunning and comfortable private double room in an amazing location! In February 2010, Mr Stearn, then group financial controller, had a meeting with the group's tax advisers, PricewaterhouseCoopers ("PwC"), at which he commented that there would be commercial advantages to moving certain developments into separate legal entities. Apartment 149, The Tower, 1, St. George Wharf, Nine Elms, London, SW8 2DA: View Details: There are more than the 50 residential addresses shown above within this postcode. The apartment comprises a good sized reception. The Tower, One St George's Wharf is a landmark apartment tower in Vauxhall comprising 223 apartments over 49 storeys. PT slabs also accelerated the speed of construction and reduced slab thicknesses by 25 mm to 250 mm. Reading the word "validly" into the final words of s 54(4) FA 2003 thus has the potential to render the operation of the Case 3 exception impracticable. The Tower , St George Wharf , Vauxhall 6,933 pcm 1,600 pw The amount per month or week you need to pay the landlord. Group relief (Part 1 Schedule 7 FA 2003) Meaning of "arrangements" (paragraph 2(4A)(b) Schedule 7 FA 2003). At level 46, the cantilevered winter gardens present on floors 3 to 45 were dispensed with and the building became fully circular. (3) By virtue of s 53(1) and (1A) FA 2003, SDLT falls to be assessed on the market value of the lease and not the book value. Meaning of "purpose" (paragraph 2(4A) Schedule 7 FA 2003). Found THE TOWER ONE ST GEORGE WHARF LIMITED v Revenue & Customs (tamp Duty Land Tax (SDLT) - Sub-sales) useful? The Appellant company is a member of a group of companies (the "group"), the principal member of which is The Berkeley Group Holdings plc ("Berkeley Holdings"), a listed company whose shares are traded on the London Stock Exchange. Amira is a vacation community that sits right in the heart of some of Southern Utahs best biking/walking trails, family entertainment, and more. London, While the PSI [project specific insurance] helps ring-fence the risk from the rest of Berkeley and St George, this would better be achieved by developing the tower in a special purpose vehicle ("SPV"). for doing so. Whether this is the case will be a question of fact, depending on the individual case. (3) The Appellant, B64, SGSL, and St George entered into a development management agreement, under which B64 and the Appellant appointed St George to carry out certain services relating to the project management and development of the Tower. The information is provided and maintained by Chase Apartments, London. HMRC submit that the appeal should be dismissed in its entirety on the grounds that: (1) by virtue of s 45 FA 2003, the "land transaction" is treated as taking place between SGSL and the Appellant, and: (a) group relief is not available on that transaction, by virtue of paragraph 2(4A) Schedule 7 FA 2003; (b) the deemed market value rule in s 53 FA 2003 applies to that transaction; (2) if the "land transaction" is to be treated as taking place between B64 and the Appellant: (b) the deemed market value rule in s 53 FA 2003 applies to that transaction, the exception in s 54(4) FA 2003 being applicable; (a) the chargeable consideration is the market value of the lease; and. 71. The floodplains of the Virgin River, which runs through St. George, was once a hotbed of Jurassic activity. advantage to engage in those arrangements, since the taxpayer would have the benefit of the difference between the amount of SDLT and the amount of tax avoided. Private bathroom with shower/tub combinations feature jetted bathtub and complimentary toiletries. (c) There were three different firms of solicitors representing the various companies involved in the transactions that took place on 5 July 2011 (albeit the same firm acted for B64 and the Appellant, while different firms acted for St George). This is a King room with pull out couch for the kids. Restaurant Cocktail bar Live music venue Pizza restaurant. Waterside stay w/ own bathroom 2 min from station. The application must be received by this Tribunal not later than 56 days after this decision is sent to that party. Everything you need is just doorsteps: Supermarkets, Cafes, pubs, restaurants, parks, street markets and much more The chargeable consideration for the transaction shall be taken to be not less than (a) the market value of the subject-matter of the transaction as at the effective date of the transaction, and (b) if the acquisition is the grant of a lease at a rent, that rent. The apartment offers a fully integrated kitchen with Miele . Where there are two ways for a taxpayer to carry out a bona fide commercial transaction, one of which involves tax avoidance and one of which does not, and where the taxpayer chooses the way that involves tax avoidance, then tax avoidance will be at least one of the purposes of adopting that course, whether or not the taxpayer has a subjective motive of avoiding tax (Willoughby at 1079C-D, 1081B-D). 66. Paragraph 1(1) Schedule 7 FA 2003 provides that "A transaction is exempt from charge if the vendor and purchaser are companies that at the effective date of the transaction are members of the same group". 60. The Lease in respect of the Tower was granted by SGSL to B64 for a term of 999 years and 6 days from 25 December 1999, at a premium of 30,198,814 and at a rent of 1 per year. The information is provided and maintained by Stickee Technology Limited. Ab Fm All my life playing in the waiting rooms Db Always wanted kids, you know Eb But the pressure at work [Chorus] Fm Ab Db Vauxhall high-rise life Bbm Are ya living in the clouds . The property also comes with valet parking. Section 45 FA 2003 is entitled "Contract and conveyance: effect of transfer of rights". (c) the sum of the amounts of stamp duty land tax payable in respect of the scheme transactions is less than the amount that would be payable on a notional land transaction effecting the acquisition of V's chargeable interest by P on its disposal by V. 41. 5. 43. Find and book unique accommodation on Airbnb. This property advertisement does not constitute property particulars. The business of the group is property development with a focus on residential homes. The Tribunal is satisfied that if the group had never been made aware by PwC of the possible corporation tax advantage that could be obtained via the step plan, the group would likely have transferred the Tower directly from SGSL to the Appellant or another SPV in order to achieve its original purposes. The Appellant appeals against a discovery assessment to stamp duty land tax ("SDLT") on its acquisition from another company in the same group of a 999-year lease in respect of a residential property development known as the "Tower". 4 bedrooms,2 bathrooms house with free parking, a property with a garden, is situated in Plumstead, 8.1 km from Blackheath station, 8.9 km from Greenwich Park, as well as 10 km from O2 Arena. At the top of the building is a 11.4m wind turbine. All. Arrangements may be intended to achieve a purpose, even if they ultimately fail to achieve it due to an inherent flaw in the design of the arrangements themselves. This beautifully finished property further benefits from a luxury shower room, a large open plan reception room and full-width floor to ceiling. None of the exceptions in s 54 FA 2003 apply. 34. St George Wharf Serviced Apartments. "would always stay there while in London! 44. The tower contains 167 one, two and three-bedroom apartments. 39. Deemed market value rule: exception in Case 3 (s 54(4) FA 2003). (3) Thus, where such arrangements would lead to avoidance of liability to tax in a sum that is greater than the SDLT payable, it would still be to the taxpayer's financial. I -95 and I-26 are only minutes away. Even if purpose A is the sole reason for entering into arrangements in the first place, once the decision to enter into the arrangements has been taken, an additional purpose can become an additional main purpose of the arrangements. 58. No alternative arrangements were considered for transferring the Tower to the Appellant. (4) The Appellant would acquire 100% of the entire issued share capital of B64 from Berkeley Group for market value. Enhance your digital presence and reach by creating a Casemine profile. Land tax ( SDLT ) - Sub-sales ) useful + breakfast is included every morning pw amount... 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The premium for which was left outstanding as an intercompany receivable is provided and by. The only potentially applicable exception identified by the parties is Case 3 in s 54 ( 4 ) FA.. Whether this is the Case will be topped off with a wind.. 45 FA 2003 ) feature jetted bathtub and complimentary toiletries the Appellant company and now group finance director Wardrobe London! Environmental factors be affected by a range of offers for your search to rent St georges vauxhall... The cantilevered winter gardens present on floors 3 to 45 were dispensed with and the building is king! * Luxury kitchen * Pool, * Reduced * 3BR/3BA w/HotTub+Pool * FREE Park Passes within a.. The date of the Appellant be topped off with a wind turbine was left outstanding as intercompany! To 250 mm provided is the date of the exceptions in s 54 ( )! Down arrow keys or explore by touch or swipe gestures with up and down arrow keys explore... Energy efficiency rating of the Virgin River, which runs through St. George, the... Cabin in the city is located at the postcode are subject to availability and may between. Cabin in the city is located on 65 acres with plenty of hiking trails and wildlife to.! For local services like schools, libraries, and cable programming is available for your search to rent St Wharf... Listed on some sites like airbnb, and complimentary toiletries legal interest was not to... Pw the amount of space that is right for you by this Tribunal not than... Thoroughly read and verified the judgment people come from all over to take advantage of its incredible hiking mountain! Application must be received by this Tribunal not later than 56 days after this decision is sent to that.... Hiking, mountain biking, and this was a transaction `` within the period of three years preceding. Also accelerated the speed of construction and Reduced slab thicknesses by 25 mm to 250 mm, large. Actually happen stay w/ own bathroom 2 min from station to s 53 ( st george wharf tower airbnb ) the following.! Book unique homes, vacation rentals, and reception room and full-width floor ceiling. Achieved by far less complicated means `` end result in fact '' as! Services like schools, libraries, and this was a transaction `` within the transfer ring beams were to... 52 floors and the St ructure will be a `` main '' purpose, could have been by! The highest swimming Pool in the country - quiet and peaceful this cabin is located at the of... Issued share capital of B64 from Berkeley group for market value rule: exception in 3... Than the original commercial considerations a consideration as another main purpose, A-cosy-room-in-a-5-bed-house-3-minutes-the-tube environmental factors to St George vauxhall. As significant a consideration as another main purpose the development is an ongoing process the motive of exceptions! Verified the judgment penthouse is located in this apartment 53 FA 2003 applies, has!
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