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

#3677
AJ Mussell
Keymaster

Drew, I understand the “reverse Ramsay” point to mean basically that if you apply the Ramsay principle to the two step scheme you collapse it so that there is only one tax charge. It’s the same result as applying the “Ramsay” principle as enacted in section 75A where you distil the scheme down to one sale from V to P. Ramsay is a principle of statutory interpretation so it applies regardless of whether HMRC wish to or not. There are now appeals in before the tax tribunal over the legitimacy of the second charge and some may be heard later this year.