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HMRC consultation document on SDLT

07 February 2022 / Rob Durrant-Walker
Issue: 4827 / Categories: Comment & Analysis
Teetering on the edge

Key points

  • HMRC is seeking to make SDLT paid on mixed-property purchases more equitable.
  • Since 2013 SDLT has become more complex and taxpayers and solicitors are finding the rules increasingly difficult.
  • There is a clear incentive for a taxpayer to find themselves on the commercial side of a mixed-use purchase.
  • Deadline for responses to HMRC’s condoc is 22 February 2022.

Cliff edge tax thresholds are not great for anyone’s relationship with HMRC. A case in point is that parts of the stamp duty land tax rules can produce enormous swings in outcomes which turn on a small ambiguity and interpretation regardless of a taxpayer’s intent to cause malice or not.

HMRC is doing a good thing about this and in November 2021 released its consultation document (condoc) ( on potential fixes for two such key areas in property tax. The condoc is unambiguously called Stamp Duty...

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