Sean Randall (Blick Rothenberg) examines a tribunal decision on the SDLT anti-avoidance in s 75A, which could have adverse consequences for cases where real estate is sold via corporate wrappers.
It’s the beginning not the end
More than one year after the hearing the First-tier Tribunal (Judge Aleksander) released its decision in Hannover Leasing Wachstumswerte Europa Beteiligungsgesellschaft MBH & Anor v HMRC [2019] UKFTT 262 (TC) ( Hannover ). The case is significant because it concerns the application of the SDLT general anti-avoidance rule FA 2003 s 75A to arrangements that were not tax avoidance arrangements. The tribunal found that s 75A did apply to the arrangements meaning that one of the appellants owed more than...
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Sean Randall (Blick Rothenberg) examines a tribunal decision on the SDLT anti-avoidance in s 75A, which could have adverse consequences for cases where real estate is sold via corporate wrappers.
It’s the beginning not the end
More than one year after the hearing the First-tier Tribunal (Judge Aleksander) released its decision in Hannover Leasing Wachstumswerte Europa Beteiligungsgesellschaft MBH & Anor v HMRC [2019] UKFTT 262 (TC) ( Hannover ). The case is significant because it concerns the application of the SDLT general anti-avoidance rule FA 2003 s 75A to arrangements that were not tax avoidance arrangements. The tribunal found that s 75A did apply to the arrangements meaning that one of the appellants owed more than...
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:
