Michael and Bridget Brown v The Commissioners for HM Revenue and Customs [2022] UKUT 00298 (TCC
Upper Tribunal Tax and Chancery Decision of Mr Justice Trower and Upper Tribunal Judge Timothy Herrington on 14 November 2022
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STAMP DUTY LAND TAX- avoidance scheme- arrangement under which house sold to unlimited company and then distributed to shareholders on reduction of share capital – application of s 45(3) FA 2003 to the scheme-whether determination of SDLT payable capable of imposing liability in relation to any liability arising under s 75A FA 2003