Marc Selby explains why, in light of s 75A, it may be important make a Langham v Veltema disclosure in relation to SDLT
The interpretation of tax legislation has become more uncertain because of the increasing trend for government to introduce wide sweeping anti-avoidance legislation intended to catch all avoidance schemes including those which might be devised following introduction of the anti-avoidance measure.
An early example of the trend is FA 2003 s 75A which was intended to counteract avoidance activity in SDLT for all time. It is effectively an SDLT mini-general anti-avoidance rule.
This article is not intended to include a detailed review of s 75A. However the features of that provision which have caused particular uncertainty in practice include:
the lack of any motive or purpose test thereby raising the possibility of the provision applying...
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Marc Selby explains why, in light of s 75A, it may be important make a Langham v Veltema disclosure in relation to SDLT
The interpretation of tax legislation has become more uncertain because of the increasing trend for government to introduce wide sweeping anti-avoidance legislation intended to catch all avoidance schemes including those which might be devised following introduction of the anti-avoidance measure.
An early example of the trend is FA 2003 s 75A which was intended to counteract avoidance activity in SDLT for all time. It is effectively an SDLT mini-general anti-avoidance rule.
This article is not intended to include a detailed review of s 75A. However the features of that provision which have caused particular uncertainty in practice include:
the lack of any motive or purpose test thereby raising the possibility of the provision applying...
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:
