631.Sections 417 and 418 exempt transfers by or under the Act from stamp duty and stamp duty reserve tax. Section 417 exempts transfers made by order or scheme under sections 408, 409 and 411, and transfers to prepare predecessor bodies for transfer to the GLA or a functional body. Section 418 exempts transfer schemes made by LRT for the vesting of property in subsidiaries of London Underground in order to implement the PPP.
632.Section 419 exempts TfL, the MPA, and the LFEPA from paying income tax, corporation tax and capital gains tax, by treating them as local authorities for the purposes of section 519 of the Income and Corporation Taxes Act 1988 and section 271 of the Taxation of Chargeable Gains Act 1992. The predecessor bodies of both the MPA and LFEPA – the Receiver for the Metropolitan Police District and the London Fire and Civil Defence Authority – fall within the ambit of these Acts as major precepting authorities, and do not pay tax. As a major precepting authority the GLA itself will not pay tax. The LDA will pay tax in the same way as RDAs generally.
633.This section also gives effect to Schedule 33. This Schedule provides for transfers made between LRT and TfL, and transfers made during any preceding reorganisation of LRT, to be tax neutral. It also clarifies the tax treatment of London Underground PPP agreements.
Commentary on Sections Schedule 32: London Regional Transport pension etc schemes Sections 417 to 419 and Schedule 33: Taxation