The decision at the First Tier Tribunal to strike out the appeal has ramifications for three other outstanding appeals against HMRC related to demands for unpaid stamp duty land tax (SDLT) gained through a tax avoidance scheme devised by Cornerstone Tax.

In total, up to 750 buyers availed themselves of the Cornerstone scheme, or some variant of it, HMRC told the tribunal, although many users chose to settle their tax bills rather than be pursued for payment after the publication of an adverse GAAR panel ruling in April 2023.