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Is there logic to SDLT anti-avoidance provisions?
KEY POINTS
- The SDLT anti-avoidance provisions are not restricted to tax avoidance transactions.
- The Project Blue land transactions consisted of seven separate steps.
- The difficulties of identifying the vendor and purchaser.
- The approach adopted by the First-tier Tribunal and the Upper Tribunal to identify the relevant parties.
- Could there be scenarios where there are multiple possible purchasers and vendors related to the same land transaction?
Widely phrased provisions to combat stamp duty land tax (SDLT) avoidance are contained in FA 2003 s 75A to s 75C.
But although headed “anti-avoidance” they are not expressly restricted to tax avoidance transactions.
Their scope was considered by the Upper Tribunal in Project Blue Ltd v CRC [2013] UKFTT 378 (TC).
FA 2003 s 75A (below; click image...
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