Guidance

GAAR Advisory Panel opinion of 20 January 2023: Stamp Duty Land Tax arrangements in relation to the sale and purchase of a residential property that involve a sub-sale and an annuity (enablers of defeated tax avoidance)

Use the GAAR Advisory Panel opinion on Stamp Duty Land Tax arrangements in relation to the sale and purchase of a residential property that involve a sub-sale and an annuity, to help you recognise when arrangements may be abusive tax arrangements.

From:
HM Revenue & Customs
Published
11 April 2023

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Details

Use this opinion together with the聽General Anti-Abuse Rule (GAAR)聽guidance to help you recognise when arrangements may be abusive tax arrangements.

This opinion covers Stamp Duty Land Tax arrangements in relation to the sale and purchase of a residential property that involve a sub-sale and an annuity.

The GAAR Advisory Panel opinion is that:

  • entering into the tax arrangements is not a reasonable course of action in relation to the relevant tax provisions
  • carrying out of the tax arrangements is not a reasonable course of action in relation to the relevant tax provisions

Updates to this page

Published 11 April 2023

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