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SDLT: No question of motive
Adam Craggs reports on a sub-sale case in which the Supreme Court allowed HMRC’s appeal ‘The court concluded that the combined effect of sub-sale relief under s45 and alternative property finance relief under s71A would have resulted in the transactions escaping SDLT, but for the anti-avoidance rule in s75A.’ In Project Blue Ltd v HMRC …
Cases Referenced
Cases in bold have further reading - click to view related articles.
- Barclays Mercantile Business Finance Ltd v Mawson [2004] UKHL 51
- HMRC v DV3 RS Ltd Partnership [2013] EWCA Civ 907
- Project Blue Ltd v HMRC [2018] UKSC 30