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A Frosh and others v HMRC

In A Frosh and others v HMRC [2016] UKFTT 558 (8 August 2016) the FTT refused an application for the immediate grant of a closure notice.

The appellants had implemented a scheme marketed by Cornerstone for the avoidance of SDLT relying on FA 2003 s 45 (sub-sale relief) similarly to Project Blue [2016] EWCA Civ 485.

HMRC had opened an enquiry into the SDLT returns. Following meetings and correspondence with the appellants HMRC had sent them a ‘settlement invitation’ indicating that in HMRC’s view the scheme did not work and inviting them to withdraw from the scheme and to pay the relevant SDLT. The letter also included a request for extensive documentation. The appellants’ adviser had replied to HMRC objecting to the request but HMRC had simply sent the same ‘settlement invitation’ again and the appellants had applied for a closure notice.

HMRC contended...

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