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Home Forums Patrick Cannon Should I appeal an SDLT mitigation scheme? Reply To: Should I appeal an SDLT mitigation scheme?

#3674
Drew Timmons
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Hi Patrick,

I note your reference to the Ramsay principle as a defence here.

One of the other chaps – Mr Bryant – refers to ‘reverse Ramsay’ and provides some authorities though I cannot see how they apply. Is there an authority for the reverse Ramsay principle. For example in the case being discussed in this thread where the artificial scheme has created two tax charges?

Regards
Drew