The Tower One St George Wharf Limited v The Commissioners for His Majesty's Revenue and Customs: [2024] UKUT 00373 (TCC)
Upper Tribunal Tax and Chancery Decision of Upper Tribunal Judge Zaman and Judge Bowler: 20 November 2024
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STAMP DUTY LAND TAX – group relief – arrangements of which one of the main purposes is the avoidance of liability to tax – deemed market value rule – FTT held group relief not available as one of the main purposes was the avoidance of liability to tax and that the deemed market value rule applied – appeal dismissed