Continue reading "SDLT On Sub-Sales: HMRC strikes back"
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SDLT On Sub-Sales: HMRC strikes back
Neil Warriner discusses a case with lessons for taxpayers ‘The lesson here for taxpayers from the finding on the first point is that, if structures like this are to be implemented, then they need to be implemented properly having regard to all legal issues that may affect them, not simply the tax rules.’ Despite their …
Cases Referenced
Cases in bold have further reading - click to view related articles.
- DV3 RS Ltd Partnership v HMRC [2011] UKFTT 138 (TC); [2012] UKUT 399 (TCC); [2013] EWCA Civ 907
- Holmleigh (Holdings) Ltd v Commissioners of Inland Revenue; Metropolitan Boot Co Ltd v Commissioners of Inland Revenue; Hale (Holdings) Ltd v Commissioners of Inland Revenue (1958) 46 TC 435
- Shop and Store Developments Ltd v IRC [1967] 1 All ER 42
- Vardy Properties and Vardy Properties (Teesside) Ltd v HMRC [2012] UKFTT 564 (TC)