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 Should I appeal an SDLT mitigation scheme? Reply To: Should I appeal an SDLT mitigation scheme?

#928
Justin Bryant
Guest

Re Ramsay (potentially in taxpayer’s favour to ignore transaction(s)) see: https://www.taxjournal.com/articles/taxpayer-pleads-anti-avoidance-rule-or-ramsay-50021

HMRC seem to accept this as follows from para 26 of the case in the link below:

“…He confirmed that, consistently with that submission, HMRC do not contend that the closure of Option 2 on 7th April gave rise to a chargeable gain even if Mr Schofield were then resident in the United Kingdom”

http://www.bailii.org/ew/cases/EWCA/Civ/2012/927.html

See also: http://www.bailii.org/uk/cases/UKSPC/2008/SPC00718.html