In M Murphy and another v HMRC[2024] UKFTT 947 (TC) (17 October) the FTT dismissed the appellant’s appeal finding that the effect of the sub-sale arrangements put in place by the taxpayers in an attempt to reduce the SDLT payable on the purchase of a property in fact resulted in increased chargeable consideration.
The appellants Mr and Mrs Murphy jointly purchased a property for £277 000. On the same date the sale contract was entered into the appellants entered into an agreement under which Mr Murphy agreed to sell (all but 1% of) his 57% share in the property pursuant to the sale contract to Mrs Murphy. These arrangements were intended to engage the sub-sale provisions in FA 2003 s 45 so that the property consideration for SDLT purposes was reduced to the amount given...
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In M Murphy and another v HMRC[2024] UKFTT 947 (TC) (17 October) the FTT dismissed the appellant’s appeal finding that the effect of the sub-sale arrangements put in place by the taxpayers in an attempt to reduce the SDLT payable on the purchase of a property in fact resulted in increased chargeable consideration.
The appellants Mr and Mrs Murphy jointly purchased a property for £277 000. On the same date the sale contract was entered into the appellants entered into an agreement under which Mr Murphy agreed to sell (all but 1% of) his 57% share in the property pursuant to the sale contract to Mrs Murphy. These arrangements were intended to engage the sub-sale provisions in FA 2003 s 45 so that the property consideration for SDLT purposes was reduced to the amount given...
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