Guidance

GAAR Advisory Panel opinion of 27 July 2022: Stamp Duty Land Tax arrangements in relation to the sale and purchase of a residential property, involving an alternative finance agreement and a lease agreement (enablers of defeated tax avoidance)

Use the GAAR Advisory Panel opinion on Stamp Duty Land Tax arrangements in relation to the sale and purchase of a residential property, involving an alternative finance agreement and a lease agreement, to help you recognise when arrangements may be abusive tax arrangements.

Documents

Stamp Duty Land Tax arrangements in relation to the sale and purchase of a residential property, involving an alternative finance agreement and a lease agreement — Promoter

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Stamp Duty Land Tax arrangements in relation to the sale and purchase of a residential property, involving an alternative finance agreement and a lease agreement — Manager

Request an accessible format.
If you use assistive technology (such as a screen reader) and need a version of this document in a more accessible format, please email different.format@hmrc.gov.uk. Please tell us what format you need. It will help us if you say what assistive technology you use.

Details

Use this opinion together with the General Anti-Abuse Rule (GAAR) guidance to help you recognise when arrangements may be abusive tax arrangements.

This opinion covers Stamp Duty Land Tax arrangements in relation to the sale and purchase of a residential property, involving an alternative finance agreement and a lease agreement.

The GAAR Advisory Panel opinion is that:

  • entering into the tax arrangements is not a reasonable course of action in relation to the relevant tax provisions
  • carrying out of the tax arrangements is not a reasonable course of action in relation to the relevant tax provisions

Updates to this page

Published 5 October 2022

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