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Coolatinney Developments Ltd v HMRC (and related appeals)

In Coolatinney Developments Ltd v HMRC (and related appeals) (TC01116 – 5 May) five companies submitted land transaction returns (forms SDLT1) declaring that they had entered into land transactions and that no SDLT was due. None of the companies filed an SDLT60 certificate in relation to any of the transactions.

In August 2008 HMRC wrote to the companies stating that they intended to make enquiries into the transactions. Each of HMRC’s letters wrongly stated that they intended to enquire into the ‘self-certificate’ rather than into the ‘land transaction return’.

HMRC subsequently issued notices under FA 2003 Sch 10 para 14 requiring the companies to produce documents and provide information. The companies appealed contending that the letters which HMRC had issued in August 2008 were not valid notices of enquiry under FA 2003 Sch 10 para 12.

The First-tier Tribunal...

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