Patrick Cannon looks at the application of Ramsay in SDLT and the use of reliefs for alternative finance structures
Two current issues in SDLT are: the application of Ramsay in SDLT and the use of reliefs for alternative structures.
Ramsay
The extent to which the courts would apply the Ramsay principle in SDLT is of some practical importance now that HMRC has begun referring to the principle in SDLT enquiries. For a long time HMRC Stamp Taxes did not rely on Ramsay and appeared content to amend the SDLT rules in the annual Finance Act (FA) in response to schemes intended to save SDLT that came to its attention. The...
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Patrick Cannon looks at the application of Ramsay in SDLT and the use of reliefs for alternative finance structures
Two current issues in SDLT are: the application of Ramsay in SDLT and the use of reliefs for alternative structures.
Ramsay
The extent to which the courts would apply the Ramsay principle in SDLT is of some practical importance now that HMRC has begun referring to the principle in SDLT enquiries. For a long time HMRC Stamp Taxes did not rely on Ramsay and appeared content to amend the SDLT rules in the annual Finance Act (FA) in response to schemes intended to save SDLT that came to its attention. The...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")