Excerpt from; Stamp Duty Land Tax Guide For Property Investors.

Avoidance Cases

(Case Law)

Comment: HMRC rigorously challenges tax avoidance to ensure fairness and public service funding. This involves legal actions to deter schemes that undermine the tax system.

Key Points:

  • Tax avoidance reduces resources for public services.
  • HMRC is committed to investigating and challenging tax avoidance.
  • Legal actions are taken against schemes aimed at reducing tax liabilities.

Main Principles:

  1. Fairness and Compliance: Tax avoidance is considered unfair to taxpayers who comply with the law. Ensuring everyone pays their fair share is a core principle.
  2. Legal Scrutiny: HMRC closely examines transactions suspected of tax avoidance, often leading to legal actions and reassessments.
  3. Public Funding: Preventing tax avoidance helps secure adequate funding for public services, benefiting the wider community.
  4. Anti-Avoidance Legislation: The legal framework includes specific provisions to counteract schemes designed to avoid tax liabilities, emphasising the importance of genuine commercial purposes over tax benefits.

Why HMRC Takes Tax Avoidance Seriously

(Case Law>Avoidance Cases)

➤ HMRC rigorously challenges tax avoidance to ensure fairness and adequate funding for public services, often taking legal action to deter individuals and organisations using such schemes.

Tax avoidance undermines the tax system, reducing the resources available for public services and shifting the tax burden onto those who do not use tax avoidance schemes. It’s seen as unfair to the majority of taxpayers who pay what they owe. 

HMRC is committed to identifying, investigating, and challenging tax avoidance schemes, ensuring that everyone pays their fair share. This commitment is reflected in the rigorous scrutiny of suspected tax avoidance cases and the pursuit of legal action when necessary.

In the following pages, we will review specific cases that highlight HMRC’s efforts against tax avoidance. These cases shed light on the strategies employed by some organisations to reduce their tax liabilities, the legal arguments presented by both sides, and the ultimate decisions of the tribunals. Through these cases, we gain insight into the ongoing battle against tax avoidance and the principles that guide the interpretation and application of tax law in the UK.

 

Avoidance Case: Lease Transfer Ineligible for SDLT Group Relief, Market Value Assessment Required

(Case Law>Avoidance Cases)

The Tower One St George Wharf Ltd v The Commissioners for His Majesty’s Revenue and Customs (STAMP DUTY LAND TAX – Sub-sales – Group relief) [2022] UKFTT 00154 (TC) (30 April 2022). Cite as: [2022] UKFTT 00154 (TC).

URL: https://www.bailii.org/uk/cases/UKFTT/TC/2022/TC08481.pdf 

➤ Transferring a property lease within a corporate group for tax avoidance makes it ineligible for Stamp Duty Land Tax relief, requiring a market value assessment.

Introduction The First-tier Tribunal dismissed an appeal against a Stamp Duty Land Tax (SDLT) assessment related to a property lease transfer within a corporate group, focusing on tax avoidance arrangements.

Example scenario where this case law principle is relevant In a real-life scenario, a company could transfer a property lease to another company within the same group to achieve financial flexibility and risk management. However, if the transfer is structured to also gain a significant tax advantage, it could be scrutinised under SDLT regulations, particularly if the transactions are part of a broader scheme with tax avoidance as one of its main purposes.

The legal principles agreed upon The Tribunal found that the lease transfer did not qualify for SDLT group relief due to arrangements aiming at tax avoidance, and the SDLT should be assessed based on the market value of the lease. It clarified that transactions forming part of a scheme with tax avoidance as a main purpose are ineligible for group relief, regardless of whether the tax advantage was ultimately realised.

General summary The case involved The Tower One St George Wharf Limited’s appeal against an SDLT assessment on acquiring a 999-year lease from a group company. The Tribunal concluded that the series of transactions, advised to achieve a corporation tax advantage, constituted arrangements with tax avoidance as a main purpose, disqualifying the transaction from SDLT group relief. 

It emphasised that the legality of tax avoidance schemes depends on their alignment with the intentions of Parliament and the broader context of their execution. The decision underscores the scrutiny on corporate transactions within groups, especially those structured to gain tax benefits, and reaffirms the principle that tax relief claims must align with genuine commercial purposes, not just tax avoidance.

 

Avoidance Case: SDLT Avoidance Schemes Ineffective Despite Retrospective Legislation

(Case Law>Avoidance Cases)

Redmount Trust Company Ltd v HMRC (STAMP DUTY LAND TAX – Sub-Sale Relief – Validity of Enquiry and Closure Notice) [2023] UKFTT 27 (TC) (05 January 2023). Cite as: [2023] UKFTT 27 (TC).

URL: https://www.bailii.org/uk/cases/UKFTT/TC/2022/TC08390.html 

➤ Tax avoidance schemes for Stamp Duty Land Tax don’t work, even with retrospective laws, and HMRC can still assess and enforce tax due within legal time limits.

Introduction
Redmount Trust Company Ltd’s appeals against HMRC’s Stamp Duty Land Tax (SDLT) assessments were dismissed by the First-tier Tribunal.

Example scenario where this case law principle is relevant
This case illustrates the principle’s application in situations where a company implements a tax avoidance scheme related to SDLT, which is then challenged by HMRC through retrospective legislation and assessments. The company appealed against both a closure notice and a discovery assessment related to SDLT due on a property transaction, arguing the assessments were invalid due to procedural grounds and time limits.

The legal principles agreed upon
The Tribunal found that the tax avoidance scheme was ineffective in avoiding SDLT liability, even before considering the retrospective amendment that explicitly targeted such schemes. It was determined that the company’s land transaction return was not “voluntary” but required under law, thereby validating HMRC’s enquiry and subsequent closure notice. Additionally, the Tribunal found that HMRC’s discovery assessment was validly issued within the appropriate time limits, dismissing the company’s argument that it was out of time.

General summary
The Tribunal’s analysis focused on the effectiveness of the tax avoidance scheme, the nature of the land transaction return filed by the company, and the timing of HMRC’s discovery assessment. It concluded that the scheme did not achieve its intended tax avoidance outcome, and the return filed by the company was indeed required under the SDLT legislative framework, thus allowing HMRC to enquire and amend the return through a closure notice.

 Furthermore, the Tribunal found that HMRC’s later discovery assessment was issued within the statutory time limits, addressing a new legal argument raised by the company. This decision underscores the importance of the statutory framework governing SDLT and the limited circumstances under which HMRC can issue assessments beyond the normal time limits.

Avoidance Case: Tribunal Confirms HMRC Authority: Discovery Assessments Valid Despite Officer Identification

(Case Law>Avoidance Cases)

Wilby v Revenue And Customs (Income Tax – discovery assessment – stamp duty land tax) [2022] UKFTT 348 (TC) (08 September 2022). Cite as: [2022] UKFTT 348 (TC).

URL: http://www.bailii.org/uk/cases/UKFTT/TC/2022/TC08589.html 

➤ HMRC can issue discovery assessments for under-declared Stamp Duty Land Tax based on discrepancies, without needing to specify which officer discovered the issue.

Introduction
This case involves an appeal against a discovery assessment for under-declared Stamp Duty Land Tax (SDLT).

Example scenario where this case law principle is relevant
In real estate transactions, if HMRC discovers a discrepancy between the SDLT declared and the actual transaction value recorded at the Land Registry, a discovery assessment can be issued to recover the under declared tax.

The legal principles agreed upon
The tribunal confirmed that HMRC has the authority to issue a discovery assessment when there is a significant mismatch between the SDLT return and the Land Registry records. The assessment’s validity does not hinge on identifying the specific HMRC officer who made the discovery, provided the decision was made following a structured and controlled process.

General summary
The tribunal dismissed the appeal, supporting HMRC’s decision to issue a discovery assessment for £21,700 in under-declared SDLT. The case centred on the purchase of a property in Harrogate, North Yorkshire, where the SDLT return significantly understated the transaction value compared to the Land Registry records. 

The tribunal found that HMRC’s process for identifying discrepancies was sufficiently rigorous to justify the assessment. It was determined that an HMRC officer had indeed made a discovery of under-declared tax, fulfilling both subjective and objective tests for issuing a discovery assessment. 

The tribunal’s decision underscores the importance of accurately declaring transaction values in SDLT returns and confirms the legal framework supporting HMRC’s authority to correct under declarations through discovery assessments.

Avoidance Case: HMRC Authorised to Issue Discovery Assessments for SDLT Underpayments

(Case Law>Avoidance Cases)

Bertelsen v Revenue & Customs (STAMP DUTY LAND TAX) [2021] UKFTT 76 (TC) (18 March 2021). Cite as: [2021] UKFTT 76 (TC).

URL: http://www.bailii.org/uk/cases/UKFTT/TC/2021/TC08061.html 

➤ HMRC can issue discovery assessments for underpaid Stamp Duty Land Tax due to complex transactions if the taxpayer hasn’t fully disclosed the details within the enquiry window.

Introduction
The Bertelsen case revolves around an appeal against discovery assessments for Stamp Duty Land Tax (SDLT) issued by HMRC.

Example scenario where this case law principle is relevant
This principle applies in situations where property transactions involve complex legal structures aimed at reducing SDLT liability. For instance, if a couple acquires a property and employs specific legal mechanisms to declare a lower tax, HMRC may issue discovery assessments if it later identifies an underpayment of tax due to these arrangements.

The legal principles agreed upon
The tribunal confirmed that HMRC is entitled to issue discovery assessments if it finds an underpayment of SDLT due to complex transaction structures, provided the discovery is made within the relevant time limits and the taxpayer hasn’t made a full and frank disclosure within the enquiry window.

General summary
The Bertelsens appealed against discovery assessments related to their acquisition of a residential property, arguing they had disclosed the transactions within the enquiry window and that any discovery by HMRC had become “stale.” 

The tribunal found that HMRC made a valid discovery of an underpayment of SDLT in November 2011, after identifying the Bertelsens as participants in a scheme designed to avoid SDLT. The tribunal determined that the information provided by the Bertelsens, although sent to HMRC, was not sufficient to preclude the discovery assessments. 

It was concluded that HMRC’s discovery was timely and not “stale,” and that the Bertelsens’ disclosure did not meet the threshold of full and frank disclosure required to prevent HMRC from issuing the assessments. The appeal was dismissed, upholding the validity of HMRC’s discovery assessments.

 

Avoidance Case: “Key Legal Principles Defined for HMRC’s SDLT Discovery Assessments and Assessment Limitations

(Case Law>Avoidance Cases)

Gray v Revenue & Customs (STAMP DUTY : Land tax) [2019] UKFTT 213 (TC) (28 March 2019). Cite as: [2019] UKFTT 213 (TC).

URL: https://www.bailii.org/uk/cases/UKFTT/TC/2019/TC07060.html 

➤ HMRC can reassess Stamp Duty Land Tax if the initial return underreports the transaction value, provided the discrepancy wasn’t obvious from the information given at the time.

Introduction
This case involves an appeal by Mr. Timothy Gray against an additional stamp duty land tax (SDLT) assessment made by HMRC for a property purchase in Ripon, North Yorkshire.

Example scenario where this case law principle is relevant
In a scenario where a property is purchased and the SDLT return shows a nominal consideration (£1) not reflective of the actual transaction value, leading to an HMRC investigation and subsequent assessment for underpaid tax.

The legal principles agreed upon
The main legal principles established include the conditions under which HMRC can make a discovery assessment for SDLT, the importance of accurate and complete disclosure in SDLT returns, and the limitations on HMRC’s ability to assess based on information available at the time of the return.

General summary
The case centres on an SDLT return filed by Mr. Gray, showing a £1 consideration for a property whose actual purchase price was £860,000. HMRC, after identifying the discrepancy through a data matching exercise, issued a discovery assessment for an additional £34,400 in SDLT. Mr. Gray appealed, arguing there was no discovery, the discovery was stale, and HMRC was precluded from making the assessment due to restrictions in paragraph 30 Schedule 10 Finance Act 2003. The tribunal found that HMRC made a valid discovery of a loss of tax, as the information available at the time of the return did not enable an HMRC officer to be aware of the underpayment. The appeal focused on whether the information provided to HMRC, including the SDLT return and a letter purportedly sent by Mr. Gray to HMRC, was sufficient to alert them to the potential underpayment. The tribunal concluded that the information in the SDLT return did not adequately disclose the transaction details necessary for HMRC to assess the correct SDLT liability. The case highlights the importance of full and accurate disclosure in SDLT returns and supports HMRC’s use of discovery assessments in cases where underpayment of tax is identified after the initial return is processed. The decision was against Mr. Gray, with the tribunal upholding the additional SDLT assessment.

Avoidance Case: Scrutiny of Connected Party Transactions, Annuity Valuation Limits, and Anti-Avoidance Provisions”

(Case Law>Avoidance Cases)

M & M Builders (Norfolk) Ltd v Revenue & Customs (TAMP DUTY LAND TAX – whether two transactions between connected parties constitute an exchange) [2019] UKFTT 541 (TC) (19 August 2019. Cite as: [2019] UKFTT 541 (TC). 

URL: http://www.bailii.org/uk/cases/UKFTT/TC/2019/TC07335.html 

➤ Transactions between connected parties are closely checked for Stamp Duty Land Tax, focusing on true market values and preventing tax avoidance.

Introduction
 This case involves M & M Builders (Norfolk) Ltd appealing against a closure notice issued by HMRC, which amended the company’s Land Transaction Return and increased the Stamp Duty Land Tax (SDLT) due from £36,000 to £180,000 for a property transaction.
Example scenario where this case law principle is relevant In real life, this principle could apply in situations where companies engage in property transactions with connected parties, especially when trying to minimise SDLT through the valuation of annuities or exchanges between connected parties. It emphasises the importance of accurately declaring transactions and the potential consequences of anti-avoidance provisions.

The legal principles agreed upon
The tribunal agreed on several key legal principles:

  1. Transactions between connected parties must be scrutinised for SDLT purposes, especially regarding the market value of properties involved.
  2. The valuation of annuities in property transactions is limited to twelve years’ payments unless market value provisions apply.
  3. Anti-avoidance provisions (s75A Finance Act 2003) can apply if transactions result in less SDLT than would be payable on a notional transaction reflecting the actual market value.

General summary
The tribunal found that M & M Builders’ transaction did not constitute an exchange that would allow for the valuation of the property based on the annuity payments alone. Instead, because the parties were connected, the market value of the property (£1,200,000) should be considered the chargeable consideration for SDLT purposes. The tribunal dismissed the appeal, upholding HMRC’s closure notice and emphasising the application of market value provisions and anti-avoidance rules in transactions between connected parties. This case highlights the scrutiny applied to property transactions involving connected parties and the importance of considering market value and anti-avoidance provisions in determining SDLT liabilities.

Avoidance Case: Legal Precedents Set in Landmark Case on SDLT Interpretation and Anti-Avoidance Measures 

(Case Law>Avoidance Cases)

Geering & Ors v Revenue and Customs (STAMP DUTY : Land tax) [2018] UKFTT 233 (TC) (23 April 2018). Cite as: [2018] STI 1170, [2018] UKFTT 233 (TC), [2018] SFTD 1115.

URL: https://www.bailii.org/uk/cases/UKFTT/TC/2018/TC06466.html 

➤ Complex property purchase schemes to avoid Stamp Duty Land Tax can be caught by anti-avoidance laws, considering money for shares as indirect payment.

Introduction
This case involves an appeal against Stamp Duty Land Tax (SDLT) determinations related to a property purchase avoidance scheme.

Example scenario where this case law principle is relevant
In real life, this principle could apply to situations where individuals or entities attempt to use complex schemes involving unlimited companies and distributions in specie to avoid paying SDLT on property transactions.

The legal principles agreed upon
The main legal principles established in this case include the interpretation of indirect consideration under s 45(3)(b)(i) of the Finance Act 2003 in the context of SDLT, and the application of the anti-avoidance provision s 75A of the same act. The tribunal found that contributions for shares could be considered indirect consideration for property purchases, and that the anti-avoidance rules could apply to transactions designed to reduce SDLT liability.

General summary
The Geering & Ors v Revenue and Customs case revolved around appeals against SDLT determinations issued by HMRC. The appellants participated in a marketed avoidance scheme involving the purchase of properties by unlimited companies, followed by a reduction in capital and distribution in specie of the property to avoid SDLT. The tribunal examined whether contributions for shares constituted indirect consideration for the purchase of property and whether the anti-avoidance rules in s 75A were engaged. It was determined that the scheme transactions were pre-ordained with the intention that monies paid for share subscriptions would be used to purchase properties, thereby constituting indirect consideration. Furthermore, the tribunal found that the anti-avoidance provision s 75A applied, resulting in the transactions being disregarded for SDLT purposes, and a notional land transaction affecting the acquisition of the chargeable interest by the purchaser was deemed to have occurred. 

This decision highlights the careful scrutiny applied to avoidance schemes and the interpretation of SDLT legislation, reinforcing the principle that indirect contributions can be considered as consideration for property transactions within the context of SDLT.

Avoidance Case: Tribunal Clarifies SDLT Laws, Emphasising Timing, Nature of Transactions, and Statutory Obligations

(Case Law>Avoidance Cases)

Crest Nicholson Operations Ltd v Revenue and Customs (STAMP DUTY : Land tax) [2017] UKFTT 135 (TC) (01 February 2017). Cite as: [2017] UKFTT 135 (TC. 

URL: http://www.bailii.org/uk/cases/UKFTT/TC/2017/TC05629.html 

➤ Complex schemes to reduce Stamp Duty Land Tax through corporate actions are scrutinised, emphasising the timing, nature of transactions, and legal obligations.

Introduction
This case involves Crest Nicholson Operations Ltd and its subsidiaries’ appeal against Stamp Duty Land Tax (SDLT) determinations and an assessment made by HM Revenue and Customs (HMRC).

Example scenario where this case law principle is relevant
In a real estate development scenario, a company might attempt to reduce SDLT liability through corporate restructuring and property transfer schemes. This case illustrates the legal scrutiny such arrangements can undergo, particularly regarding the application of SDLT laws and the roles of entities within a corporate group.

The legal principles agreed upon
The tribunal clarified the application of SDLT laws, particularly focusing on the concepts of “bare trust,” “undisclosed agency,” and the implications of corporate actions like share capital reduction and property transfer assignments. It emphasised the importance of the timing and nature of transactions, the interpretation of contractual agreements, and the statutory obligations for SDLT returns.

General summary
The tribunal examined the complex arrangements between Crest Nicholson Operations Ltd and its subsidiaries, involving the acquisition of land and subsequent corporate actions intended to mitigate SDLT liability. The case dissected the legal definitions and obligations under SDLT legislation, scrutinising the roles and actions of the involved entities, including the execution of a “bare trust” and the implications of failing to submit SDLT returns. 

The decision underscored the necessity for clear compliance with SDLT laws, highlighting the conditions under which SDLT liabilities are determined and the potential for HMRC to issue assessments based on discoveries of tax liabilities. 

The outcome serves as a cautionary tale for companies employing intricate schemes to reduce tax liabilities, demonstrating the legal complexities and potential challenges they might face from tax authorities.

Avoidance Case: HMRC’s Enquiry Validity Upheld, No Time Limit for Closure Notice

(Case Law>Avoidance Cases)

Redmount Trust Company Ltd v Revenue and Customs (STAMP DUTY LAND TAX – land transaction return – validity of a document purporting to be a land transaction return) [2023] UKUT 68 (TCC) (16 March 2023)

https://www.bailii.org/uk/cases/UKUT/TCC/2023/68.html 

➤ HMRC can investigate SDLT returns anytime and issue closure notices without a specific deadline, challenging SDLT avoidance strategies.

Introduction
 The case involves Redmount Trust Company Ltd appealing against decisions related to stamp duty land tax (SDLT) due on a property purchase.

Example scenario where this case law principle is relevant
This principle applies in scenarios where entities engage in property transactions with arrangements intended to avoid SDLT, questioning the validity of documents and HMRC’s enquiry and closure notice timelines.

The legal principles agreed upon
The main legal principles established include the validity of HMRC’s enquiry into what was deemed a “voluntary” land transaction return and the absence of a time limit for HMRC to issue a closure notice following an enquiry.

General summary
The case centres around Redmount Trust Company Ltd’s appeal against a First Tier Tribunal (FTT) decision, which upheld HMRC’s closure notice demanding £294,000 in SDLT. 

Redmount had engaged in arrangements aiming to exploit sub-sale relief to avoid SDLT on a London property purchase. The Upper Tribunal (UT) examined whether the land transaction return filed by Redmount was voluntary, given the arrangements aimed to avoid SDLT, and whether HMRC was entitled to enquire into this return. The UT also considered if there was a time limit for HMRC to issue a closure notice after opening an enquiry. The UT concluded that HMRC was entitled to enquire into the return, regardless of its voluntary nature, as the return was filed in anticipation of it possibly being a notifiable transaction. This decision was based on the understanding that once a return is filed, HMRC has the authority to enquire into it to ascertain the correct SDLT due. Furthermore, the UT determined there was no specific time limit within which HMRC must issue a closure notice after initiating an enquiry, providing HMRC flexibility in conducting thorough investigations. This case underscores the broad scope of HMRC’s powers to enquire into SDLT returns and amend them as necessary, emphasising the importance of compliance and the challenges of SDLT avoidance schemes.

Avoidance Case: Tribunal Defines Legal Principles for SDLT Avoidance Schemes in Property Acquisition by Shareholders

(Case Law>Avoidance Cases)

Michael and Bridget Brown v Revenue and Customs (STAMP DUTY AND LAND TAX – avoidance scheme – arrangement under which house sold to unlimited company and then to shareholders on reduction of share capital) [2022] UKUT 298 (TCC) (14 November 2022). Cite as: [2022] WLR(D) 502, [2023] 4 WLR 11, [2022] STC 2115, [2022] BTC 533, [2022] UKUT 298 (TCC). 

URL: https://www.bailii.org/uk/cases/UKUT/TCC/2022/298.html 

➤ SDLT avoidance involving corporate structures and property transfers to shareholders is closely scrutinised, focusing on the real economic transactions and appropriate tax charges.

Introduction
This case involves Mr. and Mrs. Brown’s appeal against a decision imposing a liability for Stamp Duty Land Tax (SDLT) on them due to their acquisition of a house through a complex avoidance scheme.
Example scenario where this case law principle is relevant
In a real-life scenario, this principle could apply to individuals attempting to use corporate structures and financial manoeuvres to avoid SDLT on property transactions, particularly where properties are transferred through companies to individuals in a way that seeks to exploit tax relief provisions.
The legal principles agreed upon
The main legal principles established in this case revolve around the application of SDLT avoidance schemes, specifically how SDLT liabilities are determined when properties are acquired through companies by shareholders. The tribunal clarified the interpretation of “consideration” in the context of SDLT, particularly focusing on transactions involving sub-sales and the distribution of property as part of a company’s share capital reduction.

General summary
The Browns attempted to avoid SDLT on the purchase of a house by first selling it to a company they owned and then transferring it to themselves as shareholders upon the reduction of the company’s share capital. This scheme aimed to exploit SDLT relief provisions for sub-sales. However, the tribunal found that the SDLT liability should be calculated based on the actual consideration paid for the property, including the amount paid to acquire shares in the company used to purchase the house. This decision emphasises the tribunal’s approach to interpreting tax legislation in a way that counters avoidance schemes, ensuring that transactions reflecting the economic reality are subject to appropriate tax charges. The case underscores the principle that SDLT planning involving artificial structures and pre-ordained series of transactions designed to exploit statutory reliefs will be closely scrutinised, with a focus on the substance over form to determine the true tax liability.

Avoidance Case: Tribunal Empowered to Issue Closure Notice: Balancing HMRC’s Tax Collection with Taxpayer Rights

(Case Law>Avoidance Cases)

Frosh & Ors v Revenue and Customs (STAMP DUTY LAND TAX) [2017] UKUT 320 (TCC) (8 August 2017). Cite as: [2017] BTC 530, [2017] STI 1859, [2017] STC 1941, [2017] UKUT 320 (TCC)

URL: https://www.bailii.org/uk/cases/UKUT/TCC/2017/320.html 

➤ Tribunals balance HMRC’s need to collect taxes with taxpayers’ rights, allowing continued investigations into complex tax avoidance without mandating immediate closure notices.

Introduction
This case involves an appeal against the refusal to issue closure notices for enquiries into Stamp Duty Land Tax (SDLT) returns.
Example scenario where this case law principle is relevant
In real estate transactions involving complex tax avoidance schemes, such as the “Project Blue scheme,” this case law principle could be applied when taxpayers seek closure notices from HMRC for their SDLT returns, indicating the end of an enquiry.
The legal principles agreed upon
The main legal principles established include the tribunal’s discretion to issue a closure notice if HMRC does not have reasonable grounds to continue an enquiry without providing a specified period. It also clarified the tribunal’s role in balancing the need for HMRC to collect tax properly and the taxpayer’s right to a timely resolution of enquiries.

General summary
The case revolved around the refusal of the First-tier Tribunal (FTT) to direct HMRC to issue closure notices for enquiries into SDLT returns related to the “Project Blue scheme,” a tax avoidance strategy. The appellants argued that HMRC had enough information to issue closure notices and that their continued enquiries were unreasonable. The Upper Tribunal examined whether HMRC had reasonable grounds for not issuing closure notices within a specified period, focusing on the legal and factual context of the SDLT planning arrangements and the specific information HMRC sought from the appellants. The tribunal highlighted the importance of HMRC having specific information about individual transactions to make informed decisions on tax liabilities, distinguishing between generic understanding of tax avoidance schemes and detailed knowledge of individual cases. It was determined that it was not unreasonable for HMRC to continue their enquiries without issuing closure notices, given the complexity of the tax avoidance scheme and the need for specific transactional information.
The decision underscored the tribunal’s discretion in handling closure notice applications and emphasised the balance between HMRC’s duty to ensure proper tax collection and the taxpayer’s interest in resolving tax enquiries promptly. The appeal was dismissed, affirming the FTT’s decision and the approach to managing enquiries into complex tax avoidance schemes.

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Mel N
3 weeks ago
Nick was fantastic to work with. I had a complicated SDLT question and he took the time to properly understand the details before giving his view. His explanations were clear, thorough, and easy to follow even on quite technical points. Would highly recommend for anyone needing land tax advice on a non-standard situation.
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stevesimmance
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Nick was really helpful; clear in his timely communications and gave candid yet entirely fair and empathetic feedback on my SDLT tax matter.... exactly as i had hoped for, he is way ahead of his competition in this regard! thoroughly recommended
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Lei Wang
1 month ago
I am extremely grateful for the professional advice and support I received. I contacted Nick regarding a particularly complex SDLT matter and was very impressed by how knowledgeable, approachable and helpful he was. He took the time to understand the circumstances, carefully considered the information provided, and gave clear and practical advice on how best to proceed. It is not often that you come across someone who is so willing to share their expertise and genuinely help others. His advice gave me much greater confidence in dealing with the matter. I would highly recommend Nick to anyone looking for someone knowledgeable, professional and genuinely helpful. Thank you again for your time and kindness!
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★★★★★ Nick was incredibly helpful in advising me on a complicated and time-sensitive SDLT issue. His responses were exceptionally prompt, clear and thorough, and he took the time to understand my individual circumstances before giving me a clear answer. I particularly appreciated that he looked at all the possible options while being completely upfront about what was and wasn’t sensible in my situation. He even advised me not to incur the cost of formal advice unless my solicitor actually required it. Professional, knowledgeable, generous with his time and genuinely helpful. I wouldn’t hesitate to recommend Nick.
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800 Lee
1 month ago
I’m very grateful for Nick’s professional and detailed advice regarding our SDLT situation. Our circumstances were quite specific and involved a previous main residence overseas and a separate rental property, so we wanted to make sure the SDLT treatment was correct. Nick took the time to carefully review the facts, explain the relevant points clearly, and provide a thorough and professional assessment. His advice gave us much more confidence about our property purchase and our SDLT position. He was also very responsive, helpful and reassuring throughout the process. I would highly recommend Nick to anyone who needs professional SDLT advice. Excellent service and very much appreciated!
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Luc
3 months ago
Nick was so fast at responding to my query. He was very polite and very informative. Although the outcome was not what we had hoped for, the advice that Nick provided was invaluable. Nick provided advice that 5 other professionals could not. I am very grateful for his help and the clarity that he gave me. Would 100% recommend. Thank you again!
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Tommy Liu
3 months ago
This is the best service I have ever used in the UK. Nick and his team were professional, friendly, responsive, and worked on a no win, no fee basis, with very reasonable fees. I contacted more than 10 tax advisers that I found on Google, and Nick was the first to respond. His reply was prompt, highly professional, and answered exactly what I was looking for. They submitted our SDLT refund claim on 4 June 2026, and we received the repayment on 10 July 2026. The whole process was smooth, efficient, and completely hassle-free. I would highly recommend Nick and his team to anyone looking for tax advice or help with an SDLT refund. Excellent service from start to finish. Well done!
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Panos Zanelis
3 months ago
I contacted Nick for guidance on a complex SDLT issue involving the transfer of a residential property to a limited company and the related implications for a new home purchase. The response I received was exceptionally detailed, clear and practical. The advice carefully explained the relevant SDLT principles, including connected-party transfers, market-value requirements, valuation evidence, the potential corporate rate and the importance of timing between transactions. What I particularly appreciated was the balanced and careful way the information was presented. It helped me understand the key risks and the practical next steps to discuss with my solicitor. The guidance was extremely useful, clearly written and provided with real care and professionalism. I am especially grateful that such a thorough initial assessment was provided free of charge. I would highly recommend their services to anyone needing specialist SDLT advice.
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Karina Spiess
4 months ago
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Maroua Mkacher
4 months ago
Nick provided an exceptionally detailed and thoughtful assessment of a very technical SDLT issue relating to property trader relief. His explanation was clear, balanced and extremely helpful, particularly around the distinction between refurbishment, repair works and minimum safety works. What I appreciated most was the level of care and nuance in the analysis rather than giving a simplistic answer, he carefully explained both the opportunities and the risks, as well as the practical evidential considerations involved. The response was comprehensive, commercially aware and easy to understand despite the complexity of the legislation. I would highly recommend Nick to anyone dealing with complex SDLT matters or property tax issues.
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francesco marra
5 months ago
I contacted Nick regarding a particularly complex SDLT issue involving overseas property ownership and higher rate SDLT implications. Unlike many other professionals I approached, who either ignored my enquiry or refused to provide any meaningful guidance because of the international aspects involved, Nick took the time to reply in detail and explain the position very clearly and professionally. His response was thorough, balanced and extremely helpful in understanding the relevant legal and practical issues before proceeding with a property purchase in London.
Yathorshan Shanthakumaran profile picture
Yathorshan Shanthakumaran
5 months ago
We were really struggling to find clear advice regarding Stamp Duty and were so relieved to come across Nick. His advice was professional, thorough, and explained in simple layman’s terms that made everything much easier to understand. What really stood out was that several solicitors we approached were either unwilling to give proper advice or would only provide rough figures for how much Stamp Duty we might have to pay, without fully exploring the legislation or our circumstances. Nick took the time to carefully look into the details and explain everything clearly and confidently. We are extremely grateful for his help and would highly recommend him to anyone needing reliable and knowledgeable Stamp Duty advice. 5 out of 5 stars from us both.
Katy Muammar profile picture
Katy Muammar
6 months ago
We are extremely grateful to Nick Garner for his outstanding help and professionalism. After other companies were unable to assist us or recover what we were entitled to, Nick handled everything with confidence, knowledge, and great attention to detail — and successfully secured the return we deserved. Despite being based in the UK while we are in Sweden, the entire process was impressively smooth. Within just a few emails, everything was clearly explained and efficiently resolved. Nick is highly professional, reliable, and truly dedicated to achieving the best outcome for his clients. We couldn’t recommend him more highly. SHADI J
Donka Dimitrova profile picture
Donka Dimitrova
7 months ago
I would like to thank Nick for the prompt and thorough responce he gave to my query. I must admit I was quite sceptical and at first I thought that the free email advise offered on the web site might well just be some sort of a bait to get you go with the paid service. I was so pleasantly surprised when I recieved a most prompt and exhaustive responce to my question. It is so refreshing to see that there are still people out there providing a highly professional pro-bono service! I cannot recommend this enough! Thanks you Nick.
Andy Morse profile picture
Andy Morse
7 months ago
Outstanding. It's easy to be slightly dubious about contacting any expert online for advice and I had a reasonably complex Stamp Duty refund question but not only did Nick come back to me within 24 hours but he also provided with the information that fully answered my query without necessarily leading me into further communication. Highly recommended for both his customer care and for his expertise.
JBTQY profile picture
JBTQY
8 months ago
Nick was superb He gave me a detailed, very clear and explanation of the SDLT situation involving the higher rates surcharge. he detailed the legislation, and reasons why I had no options – far more thorough than I expected. Knowledgeable, patient and genuinely helpful. Thank you, Nick – Ill recommend you to anyone dealing with stamp duty questions!
Ricky Puri profile picture
Ricky Puri
8 months ago
Nick is an exceptional professional — knowledgeable, honest, and highly competent. He answered my SDLT question in comprehensive detail, clearly explaining how the relevant legislation works and how it applies in practice. It’s rare to find someone who goes above and beyond to deliver such a high standard of service. Once again, thank you, Nick.
subash vanga profile picture
subash vanga
8 months ago
Nick was outstanding! He gave me an extremely detailed, clear and professional explanation of a tricky SDLT situation involving first-time buyer relief, higher rates surcharge and married couple rules. He cited the exact legislation, provided calculations, and outlined practical options – far more thorough than I expected. Highly knowledgeable, patient and genuinely helpful. Thank you, Nick – I’d recommend you to anyone dealing with stamp duty questions!
Zoe Shuker profile picture
Zoe Shuker
8 months ago
Nick was fantastic - we highly recommend him! We couldn't believe how quickly he responded to us and it explained the matter with such clarity and detail which helped us understand our position and greatly reduced our stressed! We can't thank Nick enough!
P Boyapati profile picture
P Boyapati
8 months ago
Excellent specialist advice from Nick. Who is knowledgeable, responsive, and very clear in explaining the practical risks around a mixed-use SDLT position. His guidance was thorough and realistic, which was greatly appreciated. I would confidently recommend him to others dealing with complex property tax matters.
Stevie Jacob profile picture
Stevie Jacob
9 months ago
Nick is brilliant! He is always on hand to help and his advice is always sound and honest. As a business we have over 300 investor clients and if I ever had a stamp duty query he is the only person I would recommend. Thank you Nick for your continued support and efforts
nati azar profile picture
nati azar
9 months ago
I am extremely impressed with the knowledge and level of service Nick provided—I truly can’t thank him enough for the excellent job he did. Nick advised me on SDLT where a limited company was purchasing a probate property, an area where most solicitors were unable to help. His expertise made a real difference. Thank you again.
Jacks J profile picture
Jacks J
9 months ago
Nick Garner is outstanding. I contacted him with a complex SDLT question relating to a trustee purchase under a life-interest trust, and he responded quickly with a clear, structured explanation supported by the relevant legislation. He set out the correct SDLT treatment and provided a precise calculation that removed all ambiguity for my conveyancer. Calm, highly knowledgeable and incredibly helpful. If you need SDLT advice from someone who truly understands the detail, Nick is the person to speak to.
James Harrington profile picture
James Harrington
9 months ago
Nick has been extremely, quick, clear and helpful with his advice and the full and rounded understanding of the situation, giving both sides of what can happen. He has built trust in his experience and we were very happy with his services. I would recommend Nick to and LTA to anyone going forwards.
Mike Simmons profile picture
Mike Simmons
9 months ago
Nick has been fantastically helpful. We are buying our neighbour's garage & driveway, but we simply could find no definitive answers as to whether SDLT was payable on our purchase. Nick analysed our circumstances, provided written reasonings, then provided his conclusion. We cannot recommend Nick highly enough!
Florin Gheorghiu profile picture
Florin Gheorghiu
9 months ago
Nick's prompt and clear response was invaluable - I was dealing with quite a specific edge case where I am the legal owner of a property abroad, but do not have any major interest in it, as my parents rent it out and make use of the money. The question was whether I would qualify for the SDLT first-time buy relief and whether the higher rates for SDLT apply to me. With such a specific case, I couldn't find any advice online and Nick's response gave me the confidence to proceed with our plans AND the practicalities of what documents I would need to show HMRC that my situation actually makes me a first-time buyer. Super clear and professional. Highly recommend and when we buy, I'll definitely use Nick's services for an indemnified letter. His free advice is genuinely valuable and NOT a way to get you to pay money for answers or to milk fees from you. Thanks Nick!
ivan fernandes profile picture
ivan fernandes
10 months ago
Had emailed Nick twice for some advice regarding stamp duty , the response was quick and well detailed . Did help me in taking the right course of action. Really found his advice to be very helpful
Craig Macura profile picture
Craig Macura
10 months ago
Nick provided excellent, expert advice for my SDLT enquiry. His professionalism and ability to answer specific, complex questions was extremely valuable. Thank You.
KY profile picture
KY
11 months ago
Thanks again for the help from Nick and Martin. Very professional team who have been providing detail advices and analysis, clear fee quote too before we made decision on moving forward. The whole process has taken quite along time but we have been receieving frequent updates and follow-up actions by the team. Really appreciated the help again and highly recommended their services.
Jerome Hilario profile picture
Jerome Hilario
11 months ago
Nick has been very helpful in all my queries surrounding SDLT and is extremely knowledgeable about the complexities of SDLT. I strongly recommend to use Nick for any land tax enquiries and am very much appreciative of the assistance and support he has given me
Mike D profile picture
Mike D
11 months ago
Nick was very generous and knowledgeable in providing timely and accurate advice on an SDLT query I had re the "Rule of 6". He demonstrated a real subject matter expertise. I will strongly consider proceeding with Nick to assist further with the matter.
Farhana Shabbirdin profile picture
Farhana Shabbirdin
11 months ago
Nick was outstanding from the moment he answered my call. He was incredibly knowledgeable and even provided free guidance on our complex SDLT situation. I genuinely appreciate his time, effort, and kindness in taking time out of his busy schedule to help us. Truly grateful. Thank you so much!
James profile picture
James
11 months ago
We have had some questions about how the stamp duty (SDLT) is calculated. We sent an email to Mr Garner for his advice. He quickly responded with a detailed analysis of our situation and a clear guidance. Thanks very much!
Dionne Rooney profile picture
Dionne Rooney
12 months ago
Nick was clear and answered my question in a day. I am very grateful that they were able to amass expert knowledge and share it. Such kindness helps the world go round. I will be sure to pass on my own skills to help others and make the donation to charity. Thank you so much!
Zk Ka profile picture
Zk Ka
1 year ago
Nick was incredibly helpful in explaining a complex SDLT issue. He broke everything down clearly, walked me through the calculations and options, and made the whole situation much easier to understand. Even though the outcome wasn't quite what I hoped for, his advice has given me clarity on my next steps. Professional, knowledgeable and considerate - highly recommended!
Steve Mayers profile picture
Steve Mayers
1 year ago
Nick is knowledgeable, helpful, and kind. In a brief call he quickly identified the relevant information to answer our land tax query. Combining his knowledge of the UK guidelines, and relevant case law he answered our query quickly and with confidence. Thanks!
Monika Khera profile picture
Monika Khera
1 year ago
Nick’s professional knowledge is truly commendable; complex SDLT issue was explained in such a simple language with precise reasons . It’s been an absolute pleasure knowing Nick. Highly recommend Nick.
ali shaik profile picture
ali shaik
1 year ago
I had an excellent experience with Nick. He took the time to give me a very detailed explanation, answered all of my questions thoroughly, and provided clear guidance that was easy to understand. His professionalism, patience, and support made a real difference, and I felt confident after our discussion. Highly recommended!
STEVEN SANDERS profile picture
STEVEN SANDERS
1 year ago
I would like to say a big thank you to Nick for his extremely prompt response to my emailed enquiries in relation to both SDLT and LTT including higher rate. The information Nick has provided me with is very helpful and both concise and easy to understand and will allow me to confidently move forward with my personal situation regarding property. I greatly appreciate your time and effort and highly recommend your services, thanks very much again Nick!
Zidaan Ltd profile picture
Zidaan Ltd
1 year ago
I’m extremely grateful to Nick for their prompt and expert assistance in resolving my SDLT issue. They responded quickly, clearly understood the situation, and provided practical, accurate guidance that led to a smooth resolution. Their professionalism, knowledge of the process, and ability to act efficiently made what could have been a stressful experience feel completely manageable. It’s rare to find someone so responsive and effective — I wouldn’t hesitate to recommend their services to anyone dealing with property-related matters.
Debbie Stone profile picture
Debbie Stone
1 year ago
Nick helped us with a very detailed answer in support of our son Ollie's (first time buyer) 'equity share' house purchase, for which his solicitor had mis-calculated a higher rate of SDLT (on the market value rather than the purchase price). We were desperate for a detailed enough proof of calculation to satisfy the legal team and Nick's help has saved us. Our son could not have afforded the higher rate they had miscalculated. His work is invaluable as are the causes he supports
Luke Thomas profile picture
Luke Thomas
1 year ago
Nick was a massive help with Stamp Duty issues surrounding stair casing on my flat. My solicitor was certain the remaining percentage purchase of my flat resulted in me paying Stamp Duty of a few thousand pounds. Nicks professional knowledge and expertise outlined clauses of stamp duty where I was not required to pay stamp duty for stair-casing and based upon remaining percentage being purchased. This evidence was used to relay back to my solicitor who acknowledged there would be no further action required to pay stamp duty. This saved me a few thousand pounds. Nick is highly professional, reliable, takes interest into each clients needs. Would highly recommend and will use in the future.
Alun Thomas profile picture
Alun Thomas
1 year ago
I'm absolutely delighted to have found this website and to have been able to speak with Nick !! I have been trying to make sense of the legislation for some weeks now and Nick unravelled the knots that i've mentally made of our complicated situation. He patiently listened whilst I described the multiple aspects and then explained the related schedule to each element in such an easily understandable way, happily clarifying any aspect that I was unsure of. Nick then invited me to e mail him so that he could explain in writing and refer to the relevant legislation schedule. I recieved his reply so quickly and the information was presented stage by stage with such clarity that I now feel completely confident that I know which tax is due (and which isn't !!) I can't thank or recommend Nick enough for his remarkable service. It's a huge weight lifted !! and i'm ever so grateful.
ruba sodha profile picture
ruba sodha
1 year ago
Nick called me within an hour of my contacting him. He was very thorough with understating what is a complex area of SDLT and researched the legislation in question. Very approachable. Thank you we really appreciate your help.
Sunil Kumara profile picture
Sunil Kumara
1 year ago
Nick is the best tax consultant I’ve interacted with—he responded within minutes with a clear and concise answer. He’s approachable, easy to understand, and incredibly helpful. Thank you, Nick!
Frankie Johnson profile picture
Frankie Johnson
1 year ago
Excellent service. Speedy responses to my questions from an extremely knowledgeable bloke. Would certainly recommend utilising his services.
stephanie beechey profile picture
stephanie beechey
1 year ago
Nick was very helpful on my query regarding Stamp Duty rates. He was prompt with his reply and his knowledge was excellent. I now feel less confused in this minefield of taxes. Thanks Nick
Si Wachira profile picture
Si Wachira
1 year ago
My solicitor was unable to provide advice with certainty about a specific transaction involving LBTT, a yes or no question. I struggled to find the answer myself from reading the legislation and tax advisors quoted 100s of pounds in order to research and tell me if the correct answer was yes or no. Nick responded quickly, same day and provided the answer with a detailed explanation. Exactly what I needed to comply with the legislation. Thank you so much for your help.
Dee Coman profile picture
Dee Coman
1 year ago
Nick has been very helpful. He communicated his advice very clearly. I highly recommend him for all those who have stamp duty queries. Thank you, Nick.
Ajmal Mian profile picture
Ajmal Mian
1 year ago
I asked Nick a question on stamp duty and his response was very professional setting out the condition applicable to this particular case.
Dhvanil Shah profile picture
Dhvanil Shah
1 year ago
I have recently reached out to Land Tax Advice for free of cost advice to my query related to LBTT and Additional Dwelling Supplement in Scotland. Nick thoroughly went through my case in detail, provided with a clear answer and also attached the legislation supporting the answer he provided. I would definitely recommend their service. Thanks.
Robert Harper profile picture
Robert Harper
1 year ago
Nick quickly provided exactly the sort of impartial insight that I needed and was struggling to find. It was a great help and very much appreciated.
Julie Morris profile picture
Julie Morris
1 year ago
Nick is very knowledgeable regarding this field. Not only is he knowledgeable he make it very easy to understand the minefield of stamp duty. Nick has just saved me over £7,000 in stamp duty as its not payable on my planned move. It's easy for a solicitor to say you owe X amount in stamp duty its not their hard earned money being paid out unnecessary. I will never be able to thank Nick enough. My advice is if you think your solicitor has got it wrong seek out Nick. Once again Nick thank-you so much. Take Julie
Rob Watling profile picture
Rob Watling
1 year ago
Thorough, detailed and comprehensive. Thanks
Ajay Treon profile picture
Ajay Treon
1 year ago
Amazing advice. Anyone with any SDLT queries Nick should be your goto advisor. Many thanks Nick.
Hannah Marsh profile picture
Hannah Marsh
2 years ago
I was stressed out today believing we needed to pay stamp duty on a transfer of a house when previously I didn’t think we did. I called up and asked for advice, explained my situation and that I did not understand. It was explained really clearly to me, which was so helpful. I had already tried to get advice from my accountant who did not know the answer. In fact no one seemed to know the answer until I made this phone call so I am relieved I did.
Samuel profile picture
Samuel
2 years ago
Nick was fantastic gave me some wonderful advice would definitely recommend. Thanks Nick
Lara H profile picture
Lara H
2 years ago
Needed some advice on two SDLT matters and Nick was so helpful and knowledgeable. I’d highly recommend his services, he’s a pleasure to deal with and clearly knows his stuff!
Jonathan Cockroft profile picture
Jonathan Cockroft
2 years ago
Nick is an expert in his field, knowledgeable, offering clear and concise understanding around your SDLT issue and found a prompt, informed roadmap to my individual issue. 100% speak to Nick before anyone else.
David Wong wongchisin88 profile picture
David Wong wongchisin88
2 years ago
My wife and I newly moved to the UK and encountered a problem over the eligibility of first time buyer. I contacted Nick over the phone for enquiry. Although I made the enquiry without any payment to Nick, he seriously took my case and eventually gave me very useful information, which greatly helped us to make decisions for the declaration of Stamp Duty. Throughout our communication, we definitely saw and felt Nick's passion and expertise in land tax field and professional comprehension of the law as well as very high efficiency. Seeing the information and explanation of the law given by Nick, we were certain that our simple question did cost Nick quite a bit time and efforts, yet he was all the time very polite. Seeing his true willingness and passion to help, patience, efficiency and expertise in land tax and the law, we truly admire this sage gentleman. Thank you very much Nick for helping us.
David Carter profile picture
David Carter
2 years ago
Nick is incredibly knowledgeable and was immediately able to understand my complex position in relation to UK Stamp Duty as an expat working in Switzerland. He was quick and generous in providing useful, actionable and timely advice that has allowed me to save thousands in avoidable taxation. Many thanks for your help Nick - all greatly appreciated.
Debora Depaola profile picture
Debora Depaola
2 years ago
Nick was great during our appointment, providing clear and concise clarification about stamp duty. He explained everything in an easy-to-understand way, also providing with reference to the guidance, ensuring we felt confident about the process. His professionalism, knowledge, and approachable manner made the experience seamless and stress-free. We left feeling much more confident thanks to his help! Highly recommend!
Natalia Boguslawska profile picture
Natalia Boguslawska
2 years ago
Thanks for the incredibly helpful and informative chat. Nick has patiently explained a lot, and did not dismiss my query despite the transaction being too small or not qualifying. Very knowledgeable guy, and approachable. Highly recommend!
See All Reviews
£350 NO VAT — Indemnified Letter of Advice
Fixed fee £350 for most letters. Complex cases up to £1,250 — always quoted in advance. Insured by Markel International up to £250,000 per claim.
Nick Garner

Conveyancer holding things up until they have written SDLT advice? I'll provide a formal, insured opinion from an HMRC-registered tax agent so they can proceed.

How it works

1

Email me the details of your situation. I'll reply in writing — free of charge — with a clear explanation of your legal position.

2

You decide whether that's enough. Often the free email is all you need — you can forward it to your solicitor for their own assessment.

3

If a formal letter is needed, we go from there. I'll quote you a fixed fee before any paid work begins.

Start with step 1. No commitment, no cost — just email me your situation and I'll clarify the legal position.

✉️ Email: [email protected]

Replies usually the same working day. Nick Garner, HMRC-registered tax agent.

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