UK: Stamp duty land tax general anti-avoidance rule applied to series of intra-group transactions (Court of Appeal decision)
Reflecting broad interpretation of anti-avoidance rule
The Court of Appeal held in The Tower One St George Wharf Ltd v HMRC [2025] EWCA Civ 1588 that the stamp duty land tax (SDLT) general anti-avoidance rule (section 75A FA 2003) applied to a series of intra-group land transactions carried out by the taxpayer.
The SDLT general anti-avoidance rule applies to transactions involved in connection with the disposal and acquisition of an interest in land and SDLT is reduced as a result. The court determined it appropriate to apply a broad interpretation of “involved in connection with” in determining whether the anti-avoidance rule applies.
Read a January 2026 report prepared by the KPMG member firm in the UK