(1) David Hannah (2) Carla Hodgson v The Commissioners for HM Revenue and Customs [2021] UKUT 0022 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Morgan and Judge Swami Raghavan on 2 February 2021

Read full text in

SDLT contract and conveyance effective date of land transaction contract provided for purchaser to grant an annuity annuity held on trust for purchaser pending completion of contract was contract substantially performed before completion? annuity redeemed between contract and completion what was consideration for the conveyance? application of anti-avoidance provisions - discovery assessment was discovery assessment stale? could HMRC have been reasonably expected to have been aware of insufficiency of tax? penalty notice was the inaccuracy in the return deliberate? Finance Act 2003, ss 44, 52, 75A, sch 4 para 1, sch 10 para 30, Finance Act 2007, sch 24 paras 1, 3

Updates to this page

Published 9 February 2021