[2025] UKUT 00156 (TCC) (1) Scatola and others v The Commissioners of His Majesty's Revenue and Customs

Upper Tribunal Tax and Chancery decision of Judge Cannan and Judge Jones on 27 May 2025

• From: HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
• Published: 28 May 2025

• Category: Tax
• Release date: 28 May 2025

Read full decision (1) Scatola and others v The Commissioners of His Majesty’s Revenue and Customs

STAMP DUTY LAND TAX - procedural requirements under Schedule 10, Finance Act 2003 where ineffective avoidance arrangements caught by s.75A - Enquiry Appeal - validity of notices of enquiry - understanding of reasonable recipient - Assessment Appeal - validity of discovery assessments made under extended time limit in paragraph 31(2A)(b) - whether Appellants failed to file a return in respect of the notional transaction pursuant to s75A

Published 28 May 2025