Take part in the SDLT discussion forum and give feedback. Sign up to submit that question you've wanted to ask or to share your experience or an outcome to a point of law or practice that may be puzzling the rest of us.

Home Forums Patrick Cannon SDLT Mitigation Schemes involving option arrangements Reply To: SDLT Mitigation Schemes involving option arrangements

#1728
AJ Mussell
Keymaster

Simon, thanks and yes I have one at the moment that is slowly working its way through to tribunal and am advising on others at various stages. It is very difficult to predict the chances of success given the unpredictability of the appeals process and the attitudes of different judges. I am heartened generally though by this week’s Tax Journal which reports a successful tax judicial review ( R on the application of Vacation Rentals (UK) v HMRC [2018} UKUT 383)), a successful appeal against SDLT late filing penalties (SA Jagger v HMRC [2018] UKFTT 623) and a successful appeal against an APN penalty (K Graham v HMRC [2018} UKFTT 661). There is hope yet to lift the gloom of these dark December days!