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Lessons on SDLT overpayment relief from BTR Core Fund JPUT
John Shallcross
John Shallcross (Blake Morgan) sets out what can be learnt from a recent decision where the FTT held HMRC could refuse to give effect to an overpayment relief claim for SDLT involving MDR for mixed property.
Brindleyplace Holdings: is s 75A (Hann)over now?
Edward Hardy
Helen Coward
Helen Coward and Edward Hardy (Simmons & Simmons) examine a
recent FTT decision on SDLT, property investment partnerships and the
anti-avoidance rule in s 75A.
SDLT: gardens, grounds and grazing
Max Schofield
Max Schofield (Devereux Chambers) reviews recent case law on whether land
sold with the property is ‘non-residential’, rather than part of the grounds of
the house, for SDLT purposes.
SDLT and partnerships
Susan Dennis
Adam Kay
The SDLT partnerships rules are complex, with many areas of uncertainty. Adam Kay and Susan Dennis (Saffery) review some of the traps to be aware of.
Financial services SDRT: it’s not you, it’s me
Suzi Evans
Many fear financial services SDRT. Suzi Evans (Alpine Edge Consulting) considers how the cause of that fear may not lie within the legislation.
What exactly is a ‘land transaction’ for SDLT purposes?
Paul Clark
John Shallcross
The meaning of ‘land transaction’ is more important than ever. Paul Clark (Cripps) and John Shallcross (Blake Morgan) explore the issues, with examples.
SDLT linked transactions: a long-term relationship
Leigh Sayliss
Leigh Sayliss (Memery Crystal) considers the effects that changes in one linked transaction can have on others.
The stamp duty lottery for alternative property finance providers
Sean Randall
The SDLT exemptions for alternative property finance need to be updated to give parity with conventional mortgages. Without change, SDLT will distort the market, warns Sean Randall (Blick Rothenberg).
Ask an expert: A case study on de-enveloping
Marc Selby
If a property is to be de-enveloped, the tax implications should be considered holistically and all the relevant taxes should be addressed. Marc Selby (Laytons) explains how the transaction should be structured.
Ridgway, SDLT and s 75A: HMRC giveth and taketh away
Patrick Cannon
Patrick Cannon (Cannon Chambers) examines a recent tribunal decision on self-assessed mixed-use SDLT and the broader issue of reliance on HMRC’s published guidance.
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EDITOR'S PICK
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
1 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
2 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
3 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
4 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
5 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
6 /7
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
7 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
NEWS
Read all
HMRC manual changes: 28 February 2025
Government proposes further Finance Bill amendments, including to the temporary repatriation facility
Business rates relief for film studios
HMRC advisory fuel rates
Scottish landfill tax rates
CASES
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The executors of L Elborne deceased and others v HMRC
Chelsea Cloisters Management Ltd v HMRC
HMRC v Asset House Piccadilly Ltd
Other cases that caught our eye: 28 February 2025
A Taxpayer v HMRC
IN BRIEF
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Statutory residence: but why do you need to be here?
Ramsay reined in?
HMRC’s focus on PE firms’ VAT compliance
HMRC’s U-turn on limited partners
Salaried members update
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A Taxpayer v HMRC
HMRC v Royal Bank of Canada
Finance Bill 2025 progress
Sonder Europe and serviced apartments: TOMS or no TOMS?
B Joseph v HMRC