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KEY POINTS
- Supreme Court overturned the Court of Appeal’s decision.
- The case concerned multiple transactions on which it appeared no SDLT was payable.
- Interaction between the subsale and Ijara finance reliefs.
- Application of the legislation to the ‘SDLT world’ and the ‘real world’.
- The court decided PBL was the purchaser under FA 2003 s 75A.
The final battle in the ten-year war over the stamp duty land tax that should have been paid on Qatari Diar’s purchase of Chelsea Barracks has been won by HMRC in the Supreme Court. Lord Hodge (with whom three of the four other judges agreed) delivered the judgment (Project Blue Ltd v CRC [2018] UKSC 30) on 13 June.
Stamp duty land tax advisers have keenly followed this case in the hope that light would...
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