First-Tier Tribunal considers the application of section 75A
In Project Blue Ltd v HMRC  UKFTT 378 (TC), the First-Tier Tribunal considered for the first time the application of section 75A to a complex and high-profile property transaction.
The significance of the case is that: it is the third consecutive victory for HMRC in its battle against SDLT planning and resulted in the appellant paying more SDLT than had they not adopted any planning; HMRC did not have matters all its own way and the scope of section 75A, a wide anti-avoidance provision, has been narrowed in a couple of important respects; and it is unclear whether the taxpayer will appeal but, with fine points of law involved and £50m at stake, it would seem likely.
The tribunal decision runs to some 72 pages in total. It considers various arguments, including human rights, in addition to section 75A…
If you are registered and logged in to the site, click on the link below to read the rest of the Nabarro briefing. If not, please register or sign in with your details below.
News from Nabarro
Briefings from Nabarro
Nominet, the UK’s registry operator, has announced that, from summer 2014, shorter .uk domain names will be made available for registration.
The Safe Harbor scheme is of key importance to transatlantic trade.
Analysis from The Lawyer
Real estate continues to be the key money spinner for Nabarro, which has always been known for its work in the UK property market, (although) last year results were up across the firm. Google’s ...
A few UK200 firms – such as DWF – have managed to grow in the downturn. A few, such as Berwin Leighton Paisner, have come back stronger than ever after a wobble. Nabarro fits into neither category.