Project Blue Ltd v Revenue and Customs: UTTC 18 Dec 2014

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
[2014] UKUT 564 (TCC), [2015] STC 745, [2015] STI 244, [2015] BTC 501
Finance Act 2003 45(3)
England and Wales
At FTTTxProject Blue Ltd v Revenue and Customs FTTTx 5-Jul-2013
FTTTx STAMP DUTY LAND TAX – sale of property with subsequent Shari’a – compliant sub-sale and lease-back – no SDLT paid pursuant to sections 45(3) and 71A Finance Act 2003- application of section 75A Finance Act . .

Cited by:
At UTTCProject Blue Ltd v Revenue and Customs CA 26-May-2016
The company had purchased the site of the former Chelsea barracks. It was in turn owned by the Qatari sovereign wealth fund, which financed the purchase by a Sharia compliant loan scheme, which was implemented creating a lease and buy back . .
At UTTCProject Blue Ltd v Revenue and Customs SC 13-Jun-2018
The purchaser of land created a sub-sale and leaseback with bank so as to fund the purchase in a manner which would comply with Islamic finance principles. The Court was now asked whether purchaser or the bank were liable for stamp duty land tax on . .

Lists of cited by and citing cases may be incomplete.
Updated: 27 July 2021; Ref: scu.558973