United Kingdom Upper Tribunal (Tax and Chancery Chamber)

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You are here: BAILII >> Databases >> United Kingdom Upper Tribunal (Tax and Chancery Chamber) >> Hannah & Anor v Revenue and Customs [2021] UKUT 22 (TCC) (2 February 2021)
URL: http://www.bailii.org/uk/cases/UKUT/TCC/2021/22.html
Cite as: [2021] BTC 510, [2021] UKUT 22 (TCC), [2021] STC 436

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(1) David Hannah (2) Carla Hodgson v Revenue and Customs [2021] UKUT 22 (TCC) (2 February 2021)

SDLT- contract and conveyance - effective date of land transaction - contract provided for purchaser to grant an annuity - annuity held on trust for purchaser pending completion of contract -was contract substantially performed before completion? - annuity redeemed between contract and completion - what was consideration for the conveyance? - application of anti-avoidance provisions - discovery assessment - was discovery assessment "stale"? - could HMRC have been reasonably expected to have been aware of insufficiency of tax? - penalty notice - was the inaccuracy in the return deliberate? - Finance Act 2003, ss 44, 52, 75A, sch 4 para 1, sch 10 para 30, Finance Act 2007, sch 24 paras 1, 3

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