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The upgraded SDLT enquiry regime

Patrick Cannon provides your guide to the new regime, which has so far received little publicity from HMRC

This article describes the SDLT enquiries regime as it will exist from 1 April 2011. There has been little if any publicity or explanation from HMRC Stamp Taxes of the new enquiry rules as they relate to SDLT and so this article is intended to provide a basic guide to the updated regime.

This lack of explanation from HMRC is somewhat surprising given the recent ramping-up in the number and extent of SDLT enquiries using the new powers and the adoption of a more combative approach to SDLT avoidance by HMRC.

Indeed HMRC’s SDLT Manual does not yet reflect the new powers.

Substantial changes to the original SDLT enquiry rules in FA 2003 were made on 1 April 2010 following the revamp by HMRC of their enquiry powers using...

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