When HMRC won the DV3 case at
Appeal, it raised concerns about the use of SDLT tax relief and partnerships,
says Alex Barnes
Stamp duty land tax (SDLT) planning using sub-sales is currently
very high on HMRC's radar as evidenced by the number of cases it has
recently litigated where such planning has been used. Unfortunately
for the property purchasers involved in these cases, HMRC has now
won them all and with the additional duty recovered from those cases
being in the region of £53m, HMRC will inevitably continue to
litigate those cases where it considers aggressive SDLT planning has
been implemented.
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