Guidance

GAAR Advisory Panel opinion of 20 January 2023: Stamp Duty Land Tax arrangements in relation to the sale and purchase of a residential property that involve a sub-sale and an annuity (enablers of defeated tax avoidance)

Use the GAAR Advisory Panel opinion on Stamp Duty Land Tax arrangements in relation to the sale and purchase of a residential property that involve a sub-sale and an annuity, to help you recognise when arrangements may be abusive tax arrangements.

• From: HM Revenue & Customs
• Published: 11 April 2023

Documents

Stamp Duty Land Tax arrangements in relation to the sale and purchase of a residential property that involve a sub-sale and an annuity

ODT, 38.2 KB

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Details

Use this opinion together with the General Anti-Abuse Rule (GAAR) guidance to help you recognise when arrangements may be abusive tax arrangements.

This opinion covers Stamp Duty Land Tax arrangements in relation to the sale and purchase of a residential property that involve a sub-sale and an annuity.

The GAAR Advisory Panel opinion is that:

• entering into the tax arrangements is not a reasonable course of action in relation to the relevant tax provisions
• carrying out of the tax arrangements is not a reasonable course of action in relation to the relevant tax provisions

Published 11 April 2023