- FA 2003, s 75A does not apply to sub–sale and alternative finance structure (Project Blue v HMRC)
- Original news
- What was this case about?
- What did the court decide?
- What should tax lawyers take note of?
Tax analysis: In Project Blue the Court of Appeal held that section 75A of the Finance Act 2003 (FA 2003) did not apply to a sub–sale and alternative finance structure and that Masraf al Rayan (MAR), a Qatari bank, was liable to pay stamp duty land tax (SDLT) on the transfer of the former Chelsea Barracks (the property) to it. HMRC is now out of time to make an assessment on MAR.
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