Redmount Trust Company v HMRC – decision on SDLT sub-sale by option agreement

Redmount Trust Company v HMRC – decision on SDLT sub-sale by option agreement

Rory Mullan QC appeared for the taxpayer in its appeal concerning SDLT arrangements which were retrospectively subjected to tax. The issue arose in the context of an argument as to the validity of HMRC’s enquiries. The FTT held that the scheme was not effective even absent the retrospective changes with the result that the enquiries were validly opened.

Please see link to the judgment attached here.

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