Project Blue Limited (formerly Project Blue (Guernsey) Limited) v The Commissioners for HM Revenue and Customs: [2014] UKUT 0564 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Morgan and Judge Nowlan on 18 December 2014.
Read the full decision in
.Stamp Duty Land Tax - Sale and sub-sale of large development site – Application of Finance Act 2003, section 45(3), in the form current in 2007 and 2008 - Sub-sale to financial institution – Interpretation and application of Finance Act 2003, section 71A - Interpretation and application of anti-avoidance provisions in Finance Act 2003, sections 75A and 75B - Identification of “V” and “P” for the purposes of section 75A - Interpretation of section 75A(7) - The chargeable consideration pursuant to section 75B – Was the notional land transaction pursuant to section 75A notifiable under section 77? – Interpretation of land transaction return served by Appellant – Effect of closure notice served by HMRC - Procedural matters.