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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 (tinyurl.com/rhdjyt4). 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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