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HMRC’s refreshed guidance on FA 2003, s 75A

29 January 2020 / Patrick Cannon
Issue: 4729 / Categories: Comment & Analysis
More questions than answers

Key points

  • HMRC published the revised guidance without consulting interest groups.
  • Confusion even within the department about who its manuals are aimed at.
  • The guidance seems to undermine HMRC’s offer to provide advance clearances.
  • The manual states s 75A is to be applied as an anti-tax saving test.
  • Protecting clients from an enquiry even when the correct returns have been filed and tax paid.

On 15 January 2020 HMRC updated the pages dealing with FA 2003 s 75A in its Stamp Duty Land Tax Manual ( This refresh had been much anticipated coming in the wake of the judgment of the Supreme Court in Project Blue v CRC [2018] STC 1355. This addressed an aggressive combining of tax reliefs in an effort to avoid...

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