SDLT was introduced by FA 2003 and it was a sign of the times in 2003 that the provisions did not contain any anti-avoidance provisions of note. The first version of FA 2003 s 75A introducing notional transactions came into force in 2006 and was then replaced with the expanded ss 75A–75C in 2007 when deficiencies in the original drafting were discovered. However the notional transactions legislation in s 75A is complex and difficult to apply; just have a read of the judgments in Project Blue Ltd [2018] UKSC 30 which wound up in the Supreme Court in 2018 when the first contract was signed in April 2007.
The availability of sub-sale relief proved to be very fertile ground for promoters of SDLT schemes until...
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SDLT was introduced by FA 2003 and it was a sign of the times in 2003 that the provisions did not contain any anti-avoidance provisions of note. The first version of FA 2003 s 75A introducing notional transactions came into force in 2006 and was then replaced with the expanded ss 75A–75C in 2007 when deficiencies in the original drafting were discovered. However the notional transactions legislation in s 75A is complex and difficult to apply; just have a read of the judgments in Project Blue Ltd [2018] UKSC 30 which wound up in the Supreme Court in 2018 when the first contract was signed in April 2007.
The availability of sub-sale relief proved to be very fertile ground for promoters of SDLT schemes until...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
