Stamp duty land tax (SDLT) planning using sub-sales is currently very high on HMRC's radar as evidenced by the number of cases it has recently litigated where such planning has been used. Unfortunately for the property purchasers involved in these cases, HMRC has now won them all and with the additional duty recovered from those cases being in the region of £53m, HMRC will inevitably continue to litigate those cases where it considers aggressive SDLT planning has been implemented.
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