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6th February 2018 at 4:29 pm
#928
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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