Specialist Lawyer Expects HMRC To Appeal

HMRC has lost over £38m of Stamp Duty Land Tax (SDLT) in a significant defeat to the purchaser of the Chelsea Barracks.

The acquirer, a fund owned by the Qatar Investment Authority, bought the Chelsea Barracks in 2008 had implemented some SDLT planning to acquire the property, which HMRC challenged.

HMRC had, despite winning the previous hearing  and obtaining £38m of SDLT out of PBL, then appealed to try and increase the SDLT to £50m. The acquirer sought to reduce this to nil.

Three Court of Appeal judges decided that HMRC had pursued the wrong party for the tax.