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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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48
EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
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
NEWS
Read all
HMRC closing in on tax avoidance (again)
Finance Act 2025 enacted
MPs press ahead with NICs increases
ATED chargeable amounts increased
HMRC manual changes: 28 March 2025
CASES
Read all
HMRC v Innovative Bites Ltd and another
PD & MJ Ltd v HMRC
LR R&D LLP v HMRC
Other cases that caught our eye: 28 March 2025
Orsted West of Duddon Sands (UK) Ltd and others v HMRC
IN BRIEF
Read all
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
When is 20% not 20%?
Are multiple trusts still a viable IHT planning strategy?
MOST READ
Read all
Orsted West of Duddon Sands (UK) Ltd and others v HMRC
Concerns remain over Making Tax Digital
HMRC closing in on tax avoidance (again)
V Louwman v HMRC
HMRC manual changes: 21 March 2025