In Oisin Fanning v HMRC [2020] TC07776, the First Tier Tribunal (FTT) found that HMRC's discovery assessment was validly issued. The assessment represented a 5% SDLT charge on the purchase price of a £5 million property in London. Mr Fanning (the taxpayer) had used an avoidance scheme involving a sub-sale relief and grant of options.

The FTT found that:

The appeal was dismissed.



This particular type of SDLT tax avoidance scheme was blocked by an amendment to the legislation which took effect from 21 March 2012.


Property rental profits & losses
How are property profits taxed?

How is accommodation taxed if provided by an employer?

SDLT: Amending returns
How do I amend an SDLT return?

Stamp Duty Land Tax: Rates and allowance
What is Stamp Duty Land Tax (SDLT)? What are the rates of Stamp Duty Land Tax (SDLT)?

Stamp Duty Land Tax
What are the SDLT rates? What is exempt from SDLT? What reliefs are available?

External links

Oisin Fanning v HMRC [2020] TC07776