Generate a structured brief — facts, issues, held, reasoning, and significance — for this case in seconds. Or browse the verbatim judgment via the source links below.
STAMP DUTY LAND TAX - sub-sale relief - s45(3) FA2003 - retrospective amendment to s 45(1A) by s 194 FA 2013 - whether the scheme effective pre-amendment for the original contract to be disregarded to render the return �voluntary� - whether valid enquiry opened - whether the closure notice invalid consequent on a return being �voluntary� - whether closure notice in any event subject to a four-year time limit - s 75A FA 2003 anti-avoidance provisions - whether discovery assessment valid and within the time limit - appeals dismissed
A face-to-face hearing was not held because of the coronavirus pandemic.   Prior notice of the hearing had been published on the gov.uk website, with information about how representatives of the media or members of the public could apply to join the hearing remotely in order to observe the proceedings.� The hearing was therefore held in public.
Rory Mullan QC, instructed by Justin Bryant of Blackfriars Tax Solutions LLP, for the Appellant
Elizabeth Wilson QC, instructed by the General Counsel and Solicitor to HM Revenue and Customs, for the Respondents
             Redmount Trust Company Ltd (�the appellant�) implemented a �subsale relief� scheme which was blocked by retrospective amendments by virtue of s 194 Finance Act 2013. The matters in the conjoined appeals subsequently brought by the appellant are the following:
Auto-extracted from BAILII. Full structured brief in progress — the source links below give you the verbatim judgment in the meantime.
Multiple official and mirror sources — pick whichever loads cleanly on your network.
Common Room
0 comments · About the Common Room →
No comments yet — start the discussion.
Voted-best comments help future students and feed Caselaw's AI study tools.