9 - 19. Other companies in the group include the Berkeley Group plc ("Berkeley Group"), St George PLC ("St George"), St George (South London) Limited ("SGSL"), and Berkeley Sixty-Four Limited ("B64"). Guests agree: these vacation rentals are highly rated for location, cleanliness, and more. 92. The effective date of the transaction except where otherwise provided is the date of completion (s 119(1) FA 2003). Pool, Hot Tub, Pickle Ball, Sleeps 5-6! to . How long the landlord offers to let the property for. (6) PwC advised that for accounting purposes the Appellant would treat the acquisition of B64 and the acquisition of the Tower as a single transaction as a matter of. 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). 34- Resort Condo, Heated Pool, Hot tub, Gym. References in this decision to provisions of the FA 2003 are to the versions of those provisions as in force at the time of the transactions in issue in this appeal. Speeds can be affected by a range of technical and environmental factors. This again is because this provision operates solely according to whether or not a group relief claim was in fact made, not whether a group relief claim was entitled to be made. Chase Apartments offers a complete stress free service to our clients that include a residential sales service, with our experienced estate agents. 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. The property also comes with valet parking. All. Cabin has all you need to make your stay comfortable. 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. (b) forms part of arrangements of which the main purpose, or one of the main purposes, is the avoidance of liability to tax. In practice, that can be expected to be a workable criterion to be applied by a person subsequently seeking to rely on the Case 3 exception, at the time that they are required to complete and file their land transaction return. The only effect of paragraph 2(4A) is to deny the availability of group relief from SDLT where a transaction is part of such arrangements. About a week later, PwC prepared a discussion document (the "step plan") showing that a corporation tax advantage, in the form of a tax-free step-up from book cost to market value in the carrying value of the Tower for corporation tax purposes, could be obtained if certain steps were implemented within the group in relation to the Tower. The Tower, One St George Wharf 2,300,000. A deposit provides security for a landlord against damage, or unpaid rent by a tenant. 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"). SDLT is ordinarily charged by reference to the consideration given for the acquisition (s 50(1) FA 2003). This capital contribution took B64's assets from 1 to 1,001, and gave rise to positive distributable reserves of B64. The Tower, One St. George Wharf, Nine Elms Lane, Vauxhall, London SW8 2DU: LON/00AY/LDC/2022/0091 Residential Property Tribunal Decision of Judge Dutton on 3 August 2022 From: HM Courts &. Description a well-appointed three bedroom apartment within the award winning riverside development. It is the tallest of its kind in the UK. 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. Condo in St. George 5- Amira Resort Condo, Pool, Hot tub, Gym 78. Jamie T - St. George Wharf Tower (Official Video) Jamie T 66.5K subscribers Subscribe 1.9K Share Save 168K views 6 months ago #JamieT Tickets for Jamie's biggest show ever at Finsbury Park. purposes even if the taxpayer considers A to be more important than B. However, as to paragraph 2(4A)(b) Schedule 7 FA 2003, the transfer of the Lease from B64 to the Appellant formed part of arrangements of which one of the main purposes was avoidance of liability to tax. 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). 80. The large bathroom, full kitchen, and patio overlooking the adult pool make is a great choice for a family trip, business travel, or romantic getaway. St George carried out a phased residential development of St George Wharf. Take a seat and relax with a drink! Find parking charges, opening hours, postcode and a parking map of St George Wharf St George Wharf as well as other car parks, street parking, pay and display, parking meters and private garages for rent in London . Build To Rent Furnishing Solutions. The land transaction return filed by the Appellant in respect of its acquisition of the lease from B64 included a claim for SDLT group relief under Schedule 7 of the Finance Act 2003 ("FA 2003"), as did the land transaction return filed by B64 in respect of the initial grant of the lease by SGSL to B64. Recommended option Train Amira is a vacation community that sits right in the heart of some of Southern Utahs best biking/walking trails, family entertainment, and more. This lateral apartment comprises of open plan kitchen, and reception room ideal for entertaining, principal . Such relief must be claimed in a land transaction return or an amendment to such a return (s 62(3) FA 2003). The terms of paragraph 2(4A) Schedule 7 FA 2003 refer to the purpose of the arrangements, not the purpose of the taxpayer in entering into the arrangements. Map. A very short walk from Vauxhall Station, the pier is well used by visitors and commuters. Whether youre looking to escape the winter doldrums or indulge in unrivaled natural beauty, staying in St. Georgesvacation home rentalsis a good idea any time of the year. The PwC step plan went through several iterations, and significant professional fees were incurred for this purpose. Whether you are selling or renting your property, we strive to deliver the most successful results. for doing so. It involved a complicated series of transactions that were the result of a concerted plan. A cosy, spacious, double room, with own bathroom in our relaxing waterside apartment is located in a gated, charming neighbourhood. In view of this conclusion, there is no need to determine whether the sale of the Lease by B64 to the Appellant at book value (that is to say, at an under-value) was a "distribution of the assets of that company" for purposes of s 54(4)(a) FA 2003. 24 hours concierge. 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. 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. Section 44(1) provides that that section applies where a contract for a land transaction is entered into under which the transaction is to be completed by a conveyance. Fibre/cable services at the postcode are subject to availability and may differ between properties within a postcode. The information displayed about this property comprises a property advertisement. Thus, arrangements can have the purpose of avoidance of liability to tax, even if ultimately no liability to tax is avoided. Section 53(2) FA 2003 defines, "connected" for purposes of the section by reference to s 1122 of the Corporation Tax Act. As of March 2012 the core had risen beyond the 44th floor. Show Prices . Vauxhall (St George Wharf) Pier is located on the south bank of the River Thames near Vauxhall Bridge. As s 45 FA 2003 does not apply, the transaction on which SDLT is potentially chargeable is the transfer of the Lease from B64 to the Appellant. "Tax" here means stamp duty, income tax, corporation tax, capital gains tax or tax under this Part. Berkeley Homes Eastern Counties. Selling your property today is one of the biggest reasons to stress. It refers to group relief having been claimed by the vendor. Spacious 1 Bedroom Condo With Cute Bonus Room. The tower contains 167 one, two and three-bedroom apartments. The parties are referred to "Guidance to accompany a Decision from the First-tier Tribunal (Tax Chamber)" which accompanies and forms part of this decision notice. This document contains full findings of fact and reasons for the decision. 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). The Appellant appealed against this assessment and, following HMRC's review upholding the assessment, notified its appeal to the Tribunal on 18 May 2016. There are 7 ways to get from London Heathrow Airport (LHR) to St George Wharf Tower by train, subway, bus, taxi, car, shuttle or towncar Select an option below to see step-by-step directions and to compare ticket prices and travel times in Rome2rio's travel planner. 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. Find and book unique accommodation on Airbnb. As to s 45(1)(a) FA 2003, the circumstance described in this provision did exist. 56. 18. Two hours northeast of Las Vegas, the city of St. George is a world-class destination for outdoor adventure seekers set in the sprawling desert canyons of southwestern Utah. 60. contains alphabet). It is clear from this wording that arrangements can have more than one main purpose. 11. economic consequences that Parliament intended to be suffered by any taxpayer qualifying for such reduction in tax liability (Inland Revenue Commissioners v Willoughby [1997] 1 WLR 1071 ("Willoughby"), 1079B-G, 1081B-D). Although the legislation speaks of an "effective date of the transaction" rather than of an "effective time of the transaction", all transactions in fact take place at a specific point in time. (b) The evidence does not establish that there existed, prior to the point in time on 5 July 2011 that the Lease was actually transferred from B64 to the Appellant, any legal obligation on B64 to transfer the Lease to the Appellant, or any legal right on the part of the Appellant to require B64 to transfer the Lease to it. Even if the Appellant had had no other reason for wanting to transfer the Tower to the Appellant, the mere possibility of realising a tax advantage of this magnitude might in and of itself have arguably provided a financial incentive for the Appellant to do so. Podium Level, Colston Tower, Colston Street, Bristol BS1 4XE, United Kingdom. 67. This will be so, even if the first transaction precedes the second by only minutes, or even seconds. Private room in St. Dunstan's and Stepney Green, Comfortable places with all the essentials, Spaces that are more than just a place to sleep. (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). 72. The Tower, 1 St George Wharf, Vauxhall, London SW8 0.2 miles Nine Elms 0.4 miles Stockwell Listed on 16th Dec 2022 Call Email 1/7 1 Save 2,232 pcm 515 pw 1 1 1 1 bed flat to rent St. George Wharf, London SW8 0.1 miles St George Wharf Pier 0.1 miles Vauxhall Listed on 15th Dec 2022 Available from 23rd Jan 2023 Call Email 1/13 Save 14,500 pcm Special stairs for the luxury lower penthouse apartments are supplied. If a land transaction by which B acquires a chargeable interest from A has already been completed, s 45 will not apply to any contract or other transaction entered into by B only after such completion by which the same interest is subsequently sold or transferred to C. 49. 34. (1) The series of transactions that took place on 5 July 2011 were, collectively. This Utah museum is not only home to thousands of fossils but also life-size models of prehistoric creatures, including a dilophosaurus, a megapnosaurus, and a dimorphodon. (5) B64 and the Appellant executed a Form TR1 for the transfer of the Lease by B64 to the Appellant for a consideration of 30,248,814 (the "Transfer"), and Berkeley Group, B64 and the Appellant executed agreements for the novation in favour of the Appellant of the agreements for lease entered into with third party purchasers of the residential units in the Tower. (4) Detailed planning to this end was undertaken. Section 53 FA 2003 applies in this case. Known also as the Vauxhall Tower and the St George Wharf Tower, this vast and unlovely block variously likened to a nasal hair clipper or the Tower of Sauron from the Lord Of The. The group had bona fide commercial reasons for transferring the Tower to the Appellant company, a special purpose vehicle ("SPV"), namely 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. Project Details Fm It's hard to say Ab But I hope you're happy now [Verse] Ab Fm Born in greys, mama didn't raise no fool Db Mama, am I strong enough Eb To deal with these blues? The PwC step plan went through several iterations. Meaning of "purpose" (paragraph 2(4A) Schedule 7 FA 2003). 8 The General, Lower Guinea St, Bristol BS1 6FU, United Kingdom. It stands 180 metres above ground level and comes with its own 360 degree walkway, providing a panoramic view of London not even. The apartment sits immediately behind Greenland Dock with Canary Wharf beyond. St. George receives nearly 300 days of annual sun, and things can get pretty hot during the summer in the Mojave Desert, so be sure to pack a water bottle, sunscreen, and breathable clothing. In respect of this transaction, B64 submitted a land transaction return in which it made a group relief claim. 1BRM modern w/d hot tub/gym/Perfect Spot! 61. 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. Its also a popular launching pad for exploring some of the countrys most epic public lands, including Grand Staircase Escalante National Monument and Zion and Grand Canyon national parks. The amount per month or week you need to pay the landlord. Unit 8 Millennium Drive Leeds LS11 5BP United Kingdom, Privacy Policy 2023 CCL. 6- Green Valley Condo with King Bed, Pool, Hot Tub. (5) The Tribunal is satisfied that obtaining the tax advantage became one of the main purposes of the arrangements (paragraphs 61-70 above). The Tribunal is satisfied that nothing in the wording of this provision requires a different conclusion. 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. 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. HMRC disputed this outcome and eventually, with the agreement of the taxpayer, blocked the uplift in base cost. day, and this was a transaction "within the period of three years immediately preceding the effective date of the transaction". 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. 16 2 hours. In advance of the transactions implementing the arrangements, the necessary legal agreements were negotiated and agreed (paragraph 83(2) above), and the transactions were executed in a carefully planned sequence, in accordance with the step plan prepared by PwC. 10. 22 2 hours. 8. 38. Limited Service Property. The towns unique location between the Colorado Plateau and the Great Basin to the north means youre likely to see vivid colors of red rock mixing with green foliage and bright, blue skies. TB.Cozy&Lovely private room in an Amazing Location. SW1W 8QN. Neutral Citation: [2022] UKFTT 00154 (TC) Case Number: TC08481, London Appeal reference: TC/2016/02783 Stamp Duty Land Tax (SDLT)Sub-sales (Section 45 FA 2003)Group reliefArrangements of which one of the main purposes is the avoidance of liability to tax (paragraph 2(4A) Schedule, 7 FA 2003)Deemed market value rule (s 53 FA 2003)ExceptionsCase 3 (group relief claim made within the period of three years immediately preceding the effective date of the transaction) (s 54(4) FA 2003)Anti-avoidance (s 75A FA 2003), Heard on: 14, 15 and 16 March 2022 Judgment date: 30 April 2022, THE COMMISSIONERS FOR HER MAJESTY'S REVENUE AND CUSTOMS Respondents, For the Appellant: Malcolm Gammie QC, instructed by Herbert Smith Freehills, for the Appellant, For the Respondents: Michael Jones QC, instructed by the General Counsel and Solicitor to HM Revenue and Customs, for the Respondents, The Appellant's appeal against the discovery assessment to stamp duty land tax (SDLT) dated. 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). Lovely single room available in a shared flat in Whitechapel, in the vibrant East London! 93. 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. Given the magnitude of the expected corporation tax advantage, the Tribunal is satisfied that it would have been very important to the Appellant to ensure that the arrangements were implemented correctly to ensure that the tax advantage was in fact realised. Map. Lovely Double room In an Amazing Location!!! The expression "avoidance of liability to tax" is not defined for purposes of paragraph 2(4A) Schedule 7 FA 2003, apart from the fact that the provision makes clear that it refers to avoidance of liability to stamp duty, income tax, corporation tax, capital gains tax and/or. 131 Lambeth Road, PT slabs also accelerated the speed of construction and reduced slab thicknesses by 25 mm to 250 mm. [4][8][9], In August 2014 the tower was nominated and made the Building Design short-list for that year's Carbuncle Cup, which was ultimately awarded to Woolwich Central with St George Wharf Tower being named runner-up. THE TOWER ONE ST GEORGE WHARF LIMITED v Revenue & Customs (tamp Duty Land Tax (SDLT) - Sub-sales). St George Wharf Tower RF Image ID: 2K98A2Y Preview Image details Contributor: Electric Hand / Alamy Stock Photo File size: 57.1 MB (1.6 MB Compressed download) Releases: Model - no | Property - no Do I need a release? 9. CCL provided design support and installed its post-tensioning systems within the transfer ring beams. (4) The Appellant would acquire 100% of the entire issued share capital of B64 from Berkeley Group for market value. Description St George Wharf is a landmark riverside development spanning across 7 acres of London's hottest area of regeneration, and conveniently, just moments from London's Vauxhall Underground Station. 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". St George Wharf, situated within minutes of Victoria and Waterloo stations is in a prime location. 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. Use our proprietary AI tool CaseIQ to find other relevant judgments with just one click. 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. (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. Group relief (Part 1 Schedule 7 FA 2003) Meaning of "arrangements" (paragraph 2(4A)(b) Schedule 7 FA 2003). Main purposes of the "arrangements" (that is, the broader scheme, agreement or understanding) may include both the avoidance of tax and another purpose. Providers may increase charges. The mere fact that the specific transaction on which SDLT is said to be chargeable occurs at a later point in time than any transaction(s) having the effect of avoiding tax will therefore not preclude denial of group relief pursuant to paragraph 2(4A) Schedule 7 FA 2003, if all of those transactions form part of the same arrangements for purposes of that provision. . 70. Throughout the year, you can catch The Wharf Boat & Yacht Show, the Blue Marlin Grand Championship, and other events at The . The skyscraper is due to be completed in 2014, when it will stand 181 metres (594 ft) tall and offer 49 storeys, topped by a wind turbine which I trust will work better The business of the group is property development with a focus on residential homes. "Purpose" means the intended effect of the arrangements, not the motive of the taxpayer for wanting to achieve the intended effects. Following a review of the land transaction returns, HMRC concluded that: (1) the group relief claim made by B64 did not need to be considered because sub-sale relief was available; and. Modern room in Zone 2, London with 24hr access. Even if the achievement of this tax advantage may not have been in contemplation at the time that idea of transferring the Tower into an SPV was first raised, once the group became aware of the possibility of achieving this tax advantage it became a major consideration in the arrangements. Select an option below to see step-by-step directions and to compare ticket prices and travel times in Rome2rio's travel planner. Dimensions: 3648 x 5472 px | 30.9 x 46.3 cm | 12.2 x 18.2 inches | 300dpi Date taken: 24 October 2022 Sauna Ole57650692 west facing 3 bedroom apartment within the tower. . A determination of "purpose" therefore does not necessarily require a determination of the subjective state of mind of the taxpayer, but may be ascertainable from the terms of the arrangements themselves. The information displayed about this property comprises a property advertisement. Thus, different transactions could form part of the same "arrangements" even though they involve different participants and occur at different points in time, and even though the participants in each of the transactions are under no legal obligation to enter into any of the transactions prior to the point in time at which they actually do so. Section 53 FA 2003 is entitled "Deemed market value where transaction involves connected company". People come from all over to take advantage of its incredible hiking, mountain biking, and rock climbing. Informacin detallada del sitio web y la empresa: cudshoe.com E-LONG Art Oil Paintingoil paintings|oil painting,Portraits oil painting|oil paintings for sales|wholesale oil paintings|Custom Oil Paintings 21- St George Condo with King Bed, Pool, Hot tub!! The Tribunal is satisfied that the process that led to the series of transactions on 5 July 2011 was not originally initiated out of a motive to avoid tax. 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. Luxury Spa Retreat | Pool + Spa | 4 Guest, Beautifully Remodeled Cozy Condo - Fountain Views. 2,578 1 BE 30+ days ago Rentola Report View property St George Wharf, SW8 2AZ Cozy 1-bedroom! Standing 181 metres tall, slender and circular, and containing 212 luxury apartments, The Tower, One St George Wharf is one of the tallest, wholly residential buildings in Europe. Berkeley has never developed above 30 floors before and this was, when the planning permission was granted in 2005, the tallest residential scheme in Europe. Section 53(1) provides that that section applies where the purchaser is a company and the vendor is connected with the purchaser. Private Pool+HotTub StandAlone Luxury Home, The Sand Castle- Secluded Yard w/ Private Hottub, Brand New - Ideal Location - Long Stays Welcome, Extraordinary! Sign in or create an account to save your favourite properties or searches here, Grosvenor Waterside, 32 Gatliff Road, Belgravia, 19. Citation. [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. Interact directly with CaseMine users looking for advocates in your area of specialization. Recommended Train. This is a King room with pull out couch for the kids. "arrangements", it would suffice that, prior to the entry into any of the transactions, each of the participants in each of the transactions has an understanding that the transaction that that participant is about to enter into forms part of a scheme, agreement or understanding, and knows the main purposes thereof. Successful Winner of the 2016 & 2017 Pride in the Job Regional Award (South East, Large Builder Category), 2015 & 2018 CCS Gold Awards . Family Getaway - Spacious, Updated 1 BD/1 BA, The Shed - Centrally Located Casita w E-Bikes, Peaceful Getaway/Amazing Views/Sports Village/Zion, Treat your inner kid to a home in the trees. Standing 181 metres tall, slender and circular, and containing 212 luxury apartments, The Tower, One St George Wharf is one of the tallest, wholly residential buildings in Europe. A deposit provides security for a landlord against damage, or unpaid rent by a tenant. 30. This solely residential development made up of 52 storeys, is 185m tall and houses 212 luxury apartments. The Appellant took professional advice on steps that could be taken to achieve a significant corporation tax advantage, and then entered into a series of legal transactions to implement that advice in practice. At level 46, the cantilevered winter gardens present on floors 3 to 45 were dispensed with and the building became fully circular. It features approximately 1,400 new homes and 19,000 sqm of non-residential uses, including the 50-storey mixed-use St George Wharf Tower. - Doorstep from 24hr Bus stop. Guests agree: these stays are highly rated for location, cleanliness, and more. (2) However, pursuant to s 54(4)(b), the exception in Case 3 will not apply if the subject matter of the transaction (that is, the Lease) had, within the period of three years immediately preceding the effective date of the transaction, been the subject of a transaction in respect of which group relief was claimed by the vendor (that is, by B64). That person may not know the full circumstances of the earlier transaction in respect of which the group relief claim was made. For several transactions to be part of the same. No greater amount of SDLT would have been payable on a notional transfer of the Lease directly from SGSL to the Appellant. - 20 mins to Soho and Piccadilly Circus. These were bona fide commercial reasons, that provided a commercial benefit. The operation of. 62. 17. However, the Tribunal proceeds on the basis that the group would not have transferred the Tower to the Appellant solely for the corporation tax advantage if there had been no other commercial reason. London, 37. 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. Hotels near Holland Park Station, St Johns on Tripadvisor: Find traveller reviews, 109 candid photos, and prices for 1,979 hotels near Holland Park Station in St Johns, Isle of Man.
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