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Home Forums Patrick Cannon SDLT Demand After Appeal Made Reply To: SDLT Demand After Appeal Made

#4732
AJ Mussell
Keymaster

Hi Michael, sorry to hear of this and as you may know CDP is now defunct. The scheme that you used has to my knowledge not yet been tested in the tax tribunal so it may be worth persisting and hoping that another taxpayer has their appeal heard first so that you can then better judge your chances of success. It sounds as though HMRC were in time to issue you with their discovery assessment back in 2014. Despite HMRC’s win in the Supreme Court in Project Blue the application of the anti-avoidance rule in section 75A may not be straightforward in your type of scheme.