2011 review: stamp taxes

Five key developments of 2011 concerning stamp taxes are as follows:

1. The DV3 case

DV3 RS Limited Partnership v HMRC[2011] SFTD 531 is the first case involving an SDLT avoidance scheme to come before the tax tribunals. The case involved the purchase of the Dickens and Jones store in Regent Street in 2006 for £65m. Calling the seller A and the purchaser B B would normally have paid SDLT of £2.6m on its acquisition from A. However B used a sub-sale into partnership scheme to reduce the SDLT to nil. The scheme worked by B completing its purchase from A and immediately selling the...