Effective Date of Transfer
SDLT – contract and conveyance – effective date of land transaction – contract provided for purchaser to grant an annuity – annuity held on trust for purchaser pending completion of contract – was contract substantially performed before completion? – annuity redeemed between contract and completion – what was consideration for the conveyance? – application of anti-avoidance provisions – discovery assessment – was discovery assessment ‘stale’? – could HMRC have been reasonably expected to have been aware of insufficiency of tax? – penalty notice – was the inaccuracy in the return deliberate? – Finance Act 2003, ss 44, 52, 75A, sch 4 para 1, sch 10 para 30, Finance Act 2007, sch 24 paras 1, 3
[2021] UKUT 22 (TCC)
Bailii
England and Wales
Stamp Duty
Updated: 10 November 2021; Ref: scu.658109