FTT Decision on group relief and s.75A in SDLT
The FTT has considered the scope of the “main purpose” test in the context of group relief from SDLT and provided guidance on the operation of s.75A FA 2003. The FTT allowed the appeal of HC One, formerly a company in the Bupa group.
Jonathan Peacock KC and Edward Hellier acted for HC-One on the instructions of Slaughter and May.
Francis Fitzpatrick KC and Sarah Black acted for HMRC.
The decision can be found here.
