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Lessons from the SDLT decisions in Project Blue, DV3 and Pollen Estate

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The recent SDLT decisions in Project Blue, DV3 and Pollen Estate Trustee all illustrate the need to apply the statute to the facts in a way that accords with the perceived purpose of the legislation. The courts can read specific words into legislation where necessary to correct obvious drafting errors (Pollen), but they will not read significant provisions into legislation that it could not readily be assumed were intended by Parliament (Project Blue). Deeming provisions should be followed where they lead to an answer in line with the perceived purpose of a statute, but this can still lead to a result that is quite different from a ‘real world’ one (DV3). Purposive interpretation can work in favour of the taxpayer as well as HMRC (Pollen).

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