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 HMRC sdlt claim time limit? Reply To: HMRC sdlt claim time limit?

#4733
Justin
Guest

There is a potential argument that HMRC’s original enquiry is invalid as it was made into a voluntary return and that any subsequent “protective” discovery assessment by HMRC (assuming it was otherwise in time) would be either stale or otherwise defective per para 30 et seq of this case: http://financeandtax.decisions.tribunals.gov.uk/judgmentfiles/j11266/TC07306.pdf