Stamp Taxes R&D Team: Identifying Tax Risks and Liaising with National RIS

HMRC Stamp Taxes Research and Development Team: compliance reviews

This HMRC manual page explains an internal compliance function, not a tax relief or legal rule. HMRC’s Stamp Taxes Research and Development Team reviews information connected with stamp taxes to identify possible underpayment or avoidance, and may share risk information with other HMRC teams where wider tax concerns are suspected.

• The page is about HMRC’s compliance activity, rather than setting out taxpayer rights or the legal tests for SDLT, LBTT or LTT.
• HMRC may review information submitted for stamp tax purposes to assess whether the tax treatment appears wrong, incomplete or linked to avoidance.
• A risk review does not mean HMRC has reached a final view that the taxpayer’s position is legally incorrect.
• If HMRC thinks the facts suggest risks beyond stamp taxes, it may pass the information to other HMRC business areas, including National RIS.
• The manual gives only a high-level overview and does not explain how risky cases are selected, what information is shared, or what procedural steps follow.
• In practice, it is important that transaction records clearly support the stamp tax treatment adopted in case HMRC reviews the file later.

Scroll down for the full analysis.

HMRC Stamp Taxes Research and Development Team: what this manual page means

This page is about an internal HMRC function rather than a tax relief or charging rule. It explains that HMRC’s Stamp Taxes Research and Development Team reviews customer information to identify cases where stamp tax may have been underpaid or avoided, and may pass risk information to other parts of HMRC where wider tax risks are identified.

What this rule is about

The source material is not setting out a taxpayer entitlement or a substantive legal test for SDLT, LBTT or LTT. Instead, it describes part of HMRC’s compliance activity for stamp taxes. In practical terms, it shows that HMRC does not only process returns and payments. It also reviews information to decide whether a transaction presents a compliance risk.

The page is specifically about HMRC Stamp Taxes. In the UK tax system, that mainly points to Stamp Duty Land Tax and related stamp tax matters dealt with by HMRC. The reference to passing information to other HMRC business streams also shows that a concern identified in a land transaction may lead to wider tax scrutiny if HMRC thinks the facts suggest risks beyond stamp taxes.

What the official source says

The manual says that HMRC has a Research and Development Team within Stamp Taxes. Its main objective is to assess customer information and identify cases where there is a risk that tax has been underpaid or avoided altogether.

The source also says the team has an additional function. Where it identifies risks within Stamp Taxes that may affect other HMRC business streams, it may forward that information to National RIS.

The page is brief. It does not explain what kinds of information are reviewed, what criteria are used, what National RIS does with the information, or what procedural steps follow in any particular case.

What this means in practice

The practical message is that information given to HMRC in connection with stamp taxes may be reviewed for compliance purposes, not just recorded administratively. If HMRC sees something that suggests the tax treatment may be wrong, incomplete, or part of an avoidance arrangement, the case may be selected for further attention.

This matters because a land transaction often produces information that can be relevant beyond the immediate stamp tax return. For example, the structure of a transaction, the parties involved, the stated consideration, or the explanation for a claimed tax outcome may raise questions that HMRC thinks are relevant to other taxes or compliance risks.

The source does not say that every unusual transaction is non-compliant. It says the team identifies cases where there is a risk that tax has been underpaid or avoided. A risk review is not the same as a final conclusion. It is the start of HMRC considering whether further action may be needed.

How to analyse it

If you are trying to understand the practical effect of this page, the useful questions are:

• What information has been provided to HMRC in connection with the transaction?
• Does that information clearly support the stamp tax treatment adopted?
• Is there anything in the transaction structure that could look artificial, incomplete, or inconsistent with the tax result claimed?
• Could the same facts have relevance for other taxes or other HMRC compliance teams?
• If HMRC reviewed the file later, is there a clear record showing why the tax treatment taken was thought to be correct?

The page itself does not provide a legal test for underpayment or avoidance. Those questions have to be answered by applying the underlying legislation, any relevant case law, and any other applicable HMRC guidance. This page simply shows that HMRC has a team whose role includes looking for those risks.

Example

Illustration: a land transaction return is filed on the basis that little or no stamp tax is due because of the way the deal has been structured. The documents and information submitted to HMRC suggest a more complex arrangement involving connected parties and steps that reduce the apparent charge. The manual page indicates that HMRC’s Stamp Taxes Research and Development Team may review that information to decide whether there is a risk that tax has been underpaid or avoided. If HMRC thinks the issues may also matter for other taxes, the information may be passed on within HMRC.

Why this can be difficult in practice

The source material is very high level. It tells you that the team exists and what its broad functions are, but not how HMRC decides which cases are risky or what happens next in procedural terms. That means the page is useful mainly as an indication of HMRC’s compliance approach, not as a detailed guide to taxpayer rights or obligations.

Another difficulty is that the word “avoidance” in HMRC material can cover a wide range of situations, from arrangements HMRC views as ineffective to cases where the legal position is genuinely disputed. The page does not define the term here. So it would be wrong to treat the existence of an HMRC risk review as proof that the taxpayer’s filing position is legally incorrect.

The reference to passing information to other HMRC business streams also leaves important detail unstated. The page does not explain what thresholds apply, what information may be shared internally, or how that may affect later enquiries. It simply indicates that stamp tax information may have wider compliance significance.

Key takeaways

• This manual page describes an HMRC compliance function, not a substantive stamp tax rule.
• HMRC reviews customer information to identify possible underpayment or avoidance of stamp taxes.
• If HMRC sees wider tax risks, it may pass the information to other parts of HMRC.

This page was last updated on 24 March 2026

Useful article? You may find it helpful to read the original guidance here: Stamp Taxes R&D Team: Identifying Tax Risks and Liaising with National RIS

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