The wheels come off two SDLT planning schemes, but two charities fare better before the court. Mark Baldwin and George Cotterell examine the lessons learned from three recent SDLT decisions.
Like buses you wait ages for an SDLT case to turn up and then three come along at once.
Project Blue Ltd v HMRC [2013] UKFTT 378 (TC) HMRC v DV3 RS Ltd Partnership [2013] EWCA Civ 907 and The Pollen Estate Trustee Company Ltd and King’s College London v HMRC [2013] EWCA Civ 753 all concern different SDLT provisions. However the common key to how they were decided was statutory construction and in particular the court’s desire to come to an answer that would resonate with the (SDLT literate) man on the Clapham omnibus by giving best effect...
