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Tax law [2025] UKFTT 55 (TC)

Robinson & Anor v Revenue and Customs (TAMP DUTY LAND TAX - HMRC application to strike out)

Robinson & Anor v Revenue and Customs (TAMP DUTY LAND TAX - HMRC application to strike out) [2025] UKFTT 55 (TC) (03 January 2025)

The First-tier Tribunal struck out an SDLT appeal over a marketed subsale-and-annuity scheme, holding there was no qualifying subsale and that s 75A applied.

  • Stamp duty land tax
  • Tax avoidance
  • Pre-completion transactions
  • Anti-avoidance provisions
  • Strike out applications
  • Stamp-duty-land-tax
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Tax law [2024] UKFTT 927

G Goldsmith Ltd v Revenue and Customs (STAMP DUTY LAND TAX - pre-completion transactions - assignment of contract - what constitutes substantial performance)

G Goldsmith Ltd v Revenue and Customs (STAMP DUTY LAND TAX - pre-completion transactions - assignment of contract - what constitutes substantial performance) [2024] UKFTT 927 (TC) (18 October 2024)

The Tribunal held that Mr Goldsmith had not substantially performed the contract, but his assignment triggered a notional SDLT charge. The company’s MDR claim succeeded.

  • Stamp duty land tax
  • Pre-completion transactions
  • Assignment of contract
  • Substantial performance
  • Multiple dwellings relief
  • Stamp-duty-land-tax
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Tax law [2024] UKFTT 927 (TC)

G Goldsmith Ltd v Revenue and Customs (STAMP DUTY LAND TAX - pre-completion transactions - assignment of contract - what constitutes substantial performance)

G Goldsmith Ltd v Revenue and Customs (STAMP DUTY LAND TAX - pre-completion transactions - assignment of contract - what constitutes substantial performance) [2024] UKFTT 927 (TC) (18 October 2024)

The tribunal held that Mr Goldsmith did not substantially perform the contract before assignment, but he remained liable to SDLT on a notional land transaction. The company won MDR.

  • Stamp duty land tax
  • Pre-completion transactions
  • Assignment of contract
  • Substantial performance
  • Multiple dwellings relief
  • Stamp-duty-land-tax
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United Kingdom decisions are organised by court, judge, legal area and indexed issue so a practitioner can move from a proposition to a citable authority with the surrounding context intact.