18 December 2014
UT Decision: Project Blue v HMRC
Stamp Duty Land Tax – Sale and sub-sale of large development site – Application of Finance Act 2003, section 45(3), in the form current in 2007 and 2008 – Sub-sale to financial institution – Interpretation and application of Finance Act 2003, section 71A – Interpretation and application of anti-avoidance provisions in Finance Act 2003, sections 75A and 75B – Identification of “V” and “P” for the purposes of section 75A – Interpretation of section 75A(7) – The chargeable consideration pursuant to section 75B – Was the notional land transaction pursuant to section 75A notifiable under section 77? – Interpretation of land transaction return served by Appellant – Effect of closure notice served by HMRC – Procedural matters
Roger Thomas QC, instructed by Clifford Chance, acted for the Appellant.
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