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HMRC v DV3 RS Limited Partnership

In HMRC v DV3 RS Limited Partnership (Upper Tribunal – 6 November) a A company which was the principal member of a limited partnership (D) acquired some land and transferred it to D. HMRC issued a ruling that D was required to account for SDLT on its acquisition. D appealed contending
that the combined effect of FA 2003 s 45 and FA 2003 Sch 15 para 10 was that there was no SDLT liability. The First-Tier Tribunal accepted this contention and allowed the appeal holding that the effect of the legislation was that the consideration for D’s acquisition should be treated as nil. The Upper Tribunal upheld this decision. Henderson J observed that ‘the result is no doubt one that Parliament would not have intended had the facts of the present case been drawn to its attention’. However ‘if the transactions in...

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