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How stamp duty land tax now applies to complex transactions.
KEY POINTS
- Project Blue concerns a Shariah financed purchase on which no SDLT was paid under FA 2003 s 45(3) and s 71A.
- The Court of Appeal found for the taxpayer overturning the previous tribunal decisions.
- HMRC argued the SDLT reliefs claimed were available but in combination were undone by the anti-avoidance rule FA 2003 s 75A.
- The Court of Appeal ruled s 71A relief was not available and SDLT should have been payable but by the Shariah bank not the appellant.
- HMRC is out of time to assess the Shariah bank.
The recent Court of Appeal’s decision in Project Blue Ltd v HMRC [2016] EWCA Civ 485 came to a surprising conclusion in favour of the taxpayer. The stamp duty land tax (SDLT) planning under scrutiny has already been...
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