The notable developments this year have been: the judgment in the first SDLT avoidance case to reach the tribunals resulting in a victory for the taxpayer; the change to the rules on how SDLT applies to property exchanges and the current uncertainty this creates where VAT is involved; the new relief for acquisitions of two or more dwellings which is intended to bring the rate of SDLT into line with what it would have been on an individual sale of each dwelling; the new time limits for SDLT discovery assessments; and
an important change in HMRC’s published approach to the interpretation of the SDLT GAAR in FA 2003 s 75A.
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