Market leading insight for tax experts
View online issue

A Frosh and others v HMRC

Application for closure notice denied

In A Frosh and others v HMRC [2016] UKFTT 558 (8 August 2016) the FTT refused an application for the immediate grant of a closure notice.

The appellants had implemented a scheme marketed by Cornerstone for the avoidance of SDLT relying on FA 2003 s 45 (sub-sale relief) similarly to Project Blue [2016] EWCA Civ 485.

HMRC had opened an enquiry into the SDLT returns. Following meetings and correspondence with the appellants HMRC had sent them a ‘settlement invitation’ indicating that in HMRC’s view the scheme did not work and inviting them to withdraw from the scheme and to pay the relevant SDLT. The letter also included a request for extensive documentation. The appellants’ adviser had replied to HMRC objecting to the request but HMRC had simply sent the same ‘settlement invitation’ again and the appellants had applied for...

If you or your firm subscribes to Taxjournal.com, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
EDITOR'S PICKstar
Top