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The Controlling Tendency

Toby Price a tax director in Real Estate at Deloitte LLP says that the question of control can dominate in matters of SDLT group relief
Para 4ZA (which by the way is in FA 2003 Sch 7 but can take a bit of finding) is now one year old. Fittingly a very good summary of SDLT group relief and of the added reach which para 4ZA brings to clawback of that relief was given by Mike Dalton and Tony Hennessy recently in The Tax Journal (see Issue 968 16 February 2009).
This article picks out two areas for further attention. Both featured significantly in the HMRC guidance on para 4ZA released on 26 November 2008 and involve the concept of 'control'. In...
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