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MDR
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MDR
MDR
L-L-O Contracting Ltd and others v HMRC
Upper Tribunal denies SDLT overpayment relief
S Fitzgerald and another v HMRC
SDLT MDR denied where planning restriction existed.
Other cases that caught our eye: 1 November 2024
SDLT pre-completion transactions and substantial performance: There are several complexities in G Goldsmith Ltd and another v HMRC [2024] UKFTT 927 (TC) (18 October) of interest to SDLT practitioners. It also shows some of the dangers which arise...
Other cases that caught our eye: 18 October 2024
SDLT MDR claim denied: Shine Business Ltd v HMRC [2024] UKFTT 894 (TC) (7 October) is another in the long line of cases on the now-abolished SDLT multiple dwelling relief. Like all such appeals the decision is highly fact dependent. The FTT,...
J Winfield v HMRC
MDR appeal allowed.
Private client review for April 2024
Sam Epstein
Edward Reed
Recent decisions on mixed use SDLT, taxpayer behaviour and the meaning of
‘service’ under the remittance basis rules are reviewed by Edward Reed and
Sam Epstein (Macfarlanes).
Other cases that caught our eye: 5 April 2024
Application to strike out MDR claim rejected: HMRC has had a high level of success in appeals involving multiple dwelling and mixed used SDLT reliefs. In Newsand Ltd v HMRC [2024] UKFTT 221 (TC) (13 March 2024), HMRC sought to build on those...
HMRC v D Ridgway
Upper Tribunal rules against mixed use determination.
What exactly is a ‘land transaction’ for SDLT purposes?
Paul Clark
John Shallcross
The meaning of ‘land transaction’ is more important than ever. Paul Clark (Cripps) and John Shallcross (Blake Morgan) explore the issues, with examples.
SDLT linked transactions: a long-term relationship
Leigh Sayliss
Leigh Sayliss (Memery Crystal) considers the effects that changes in one linked transaction can have on others.
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EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
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HMRC manual changes: 18 July 2025
Chancellor outlines financial services strategy
CIOT reviews transfer pricing proposals
Marriage allowance: backdating claims
Further HMRC update on VAT penalties
CASES
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Abbotsford Property Group Ltd and another v Revenue Scotland
R (oao Thomas Holdings Ltd and others) v HMRC
G Stenhouse and another v HMRC
Other cases that caught our eye: 18 July 2025
B D’Angelin v HMRC
IN BRIEF
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HMRC’s approach to wealthy individuals
There’s only one POEM
Discovery assessments: agents
Standish v Standish
Section 899 compromise shifts international tax landscape
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‘Legislation Day’ date announced
G Haworth and others v HMRC
One Big Beautiful Bill Act enacted
Abbotsford Property Group Ltd and another v Revenue Scotland
Wealth taxes and fiscal reality