SDLT and closure notices: In Redmount Trust Company Ltd v HMRC [2023] UKUT 68 (TCC) (16 March 2023) the UT considered an appeal against the validity of a closure notice in respect of a sub-sale SDLT scheme involving an agreement to grant an option (which had been retrospectively rendered ineffective by provisions of FA 2013). The appellant argued that since at the time the land transaction return was submitted there was no notifiable transaction the return it submitted was not a valid land transaction return and accordingly HMRC could neither raise an enquiry into it nor issue a closure notice. Furthermore the appellant argued that any such closure notice was out of time by reference to the discovery assessment time limits. The UT dismissed the appeal holding that it was not material whether a land transaction return was strictly necessary in order for the potential legal consequences (including...
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