Guidance

GAAR Advisory Panel opinion of 27 July 2022: Stamp Duty Land Tax arrangements in relation to the sale and purchase of a residential property, involving an alternative finance agreement and a lease agreement (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, involving an alternative finance agreement and a lease agreement, to help you recognise when arrangements may be abusive tax arrangements.

• From: HM Revenue & Customs
• Published: 5 October 2022

Documents

Stamp Duty Land Tax arrangements in relation to the sale and purchase of a residential property, involving an alternative finance agreement and a lease agreement — Promoter

ODT, 29.6 KB

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Stamp Duty Land Tax arrangements in relation to the sale and purchase of a residential property, involving an alternative finance agreement and a lease agreement — Manager

ODT, 29.5 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, involving an alternative finance agreement and a lease agreement.

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 5 October 2022