Liz Wilson (Squire Patton Boggs) considers whether the Supreme Court’s decision shifts the boundary between acceptable and unacceptable SDLT planning.
It has been over a decade since the Ministry of Defence (MoD) sold the Chelsea Barracks. Finally on 13 June 2018 the SDLT consequences of that transaction have been resolved. Perhaps unsurprisingly the UK Supreme Court has ruled (by a majority of 4:1) to allow the appeal of HMRC: Project Blue v HMRC [2018] UKSC 30. The judgment of the Court of Appeal (CA) has been overturned. The Supreme Court ruling brings to a close finally one of the most intricate and finely balanced disputes concerning SDLT since its introduction in 2003.
The case is instructive because it:
illustrates the complexities in the operation of the relief from SDLT for transactions involving a sub-sale (and hence the need...
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Liz Wilson (Squire Patton Boggs) considers whether the Supreme Court’s decision shifts the boundary between acceptable and unacceptable SDLT planning.
It has been over a decade since the Ministry of Defence (MoD) sold the Chelsea Barracks. Finally on 13 June 2018 the SDLT consequences of that transaction have been resolved. Perhaps unsurprisingly the UK Supreme Court has ruled (by a majority of 4:1) to allow the appeal of HMRC: Project Blue v HMRC [2018] UKSC 30. The judgment of the Court of Appeal (CA) has been overturned. The Supreme Court ruling brings to a close finally one of the most intricate and finely balanced disputes concerning SDLT since its introduction in 2003.
The case is instructive because it:
illustrates the complexities in the operation of the relief from SDLT for transactions involving a sub-sale (and hence the need...
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:
