Project Blue Limited (formerly Project Blue (Guernsey) Limited) v The Commissioners for HM Revenue and Customs: [2014] UKUT 0564 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Morgan and Judge Nowlan on 18 December 2014.

Read the full decision in Project Blue Limited (formerly Project Blue (Guernsey) Limited) v The Commissioners for HM Revenue and Customs: [2014] UKUT 0564 (TCC).

Stamp Duty Land Tax - Sale and sub-sale of large development site – Application of Finance Act 2003, section 45(3), in the form current in 2007 and 2008 - Sub-sale to financial institution – Interpretation and application of Finance Act 2003, section 71A - Interpretation and application of anti-avoidance provisions in Finance Act 2003, sections 75A and 75B - Identification of “V” and “P” for the purposes of section 75A - Interpretation of section 75A(7) - The chargeable consideration pursuant to section 75B – Was the notional land transaction pursuant to section 75A notifiable under section 77? – Interpretation of land transaction return served by Appellant – Effect of closure notice served by HMRC - Procedural matters.

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