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A taxpayer business has recently won a decision against HMRC in the First Tier Tax Tribunal over an SDLT saving scheme which was put in place on a property transaction with a purchase price of about £65million. The saving relied on a combination of two SDLT reliefs, for sub-sales and for connected party transfers into partnerships.
It’s been very rare for HMRC to take SDLT cases to the courts since the introduction of SDLT in 2003, and this defeat for them may give them cause for thought over possible future court action, despite a concern amongst tax advisers that HMRC are looking strongly into challenging SDLT saving schemes.
The particular scheme used in this case may not be workable now, given that SDLT anti-avoidance legislation has been introduced since the transaction in question took place. What will be really interesting is if HMRC dare go to court in future on the grounds of that anti-avoidance legislation, so we can see if the courts will back it up.
The Chancellor, Phillip Hammond, has just delivered his latest budget and with it, a significant change to the way liability for IR35 breaches will be dealt with for private sector companies from April 2020.
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Approximately 11 million documents have been leaked from Panamanian law firm Mossack Fonseca, which specialises in commercial and trusts law…
This week sees the implementation of the Senior Managers and Certification Regimes as well as the Senior Insurance Managers Regime, designed to reform behaviour and promote individual accountability in the banking and insurance sectors.
Under the provisions of the SBEEA the holders of bearer shares have until 26 February 2016 to voluntarily surrender them to the company for conversion…
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