28 March 2023

Redmount -v- HMRC

In this case, the Upper Tribunal confirms that a valid enquiry may be opened into a protective SDLT return and that no special limitation period applies to SDLT closure notices.  The issues were decided in the context of a sub sale scheme involving an agreement to grant an option, subsequently blocked by retrospective legislation.

Elizabeth Wilson KC acted for HMRC.

To view a copy of the decision please click here

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