In The Pollen Estate Trustees Ltd v HMRC [2012] UKUT 277 (TCC), the Upper Tribunal agreed with HMRC's view that charities relief for stamp duty land tax (SDLT) is not available where land is acquired by a bare trust, and not all the trust's beneficiaries are charities. In this case a company acquired four properties and submitted a claim for a partial repayment of the SDLT it had paid on the purchases.
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