Patrick Cannon explores the new SDLT general anti-avoidance rule and how a court might interpret it in the context of HMRC's recent supplementary 'interim guidance'
Patrick Cannon explores the new SDLT general anti-avoidance rule and how a court might interpret it in the context of HMRC's recent supplementary 'interim guidance'
In the PBR on 6 December 2006 HMRC introduced by secondary legislation a general anti-avoidance rule into SDLT in the form of Finance Act 2003 s 75A. The wording of the new provision is so wide that almost any transaction which consists of more than a simple sale of land by itself could be caught and taxed on the total consideration paid for the entire transaction. In its official response to the new legislation the CIoT has said that 'the drafting of s 75A...
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Patrick Cannon explores the new SDLT general anti-avoidance rule and how a court might interpret it in the context of HMRC's recent supplementary 'interim guidance'
Patrick Cannon explores the new SDLT general anti-avoidance rule and how a court might interpret it in the context of HMRC's recent supplementary 'interim guidance'
In the PBR on 6 December 2006 HMRC introduced by secondary legislation a general anti-avoidance rule into SDLT in the form of Finance Act 2003 s 75A. The wording of the new provision is so wide that almost any transaction which consists of more than a simple sale of land by itself could be caught and taxed on the total consideration paid for the entire transaction. In its official response to the new legislation the CIoT has said that 'the drafting of s 75A...
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:
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