HMRC had made a valid discovery assessment to recover stamp duty land tax following its belief that the appellant had used a tax avoidance scheme to reduce the tax liability on the purchase of a residential property. 

Summary 

HMRC had made a valid discovery assessment to recover stamp duty land tax (SDLT) following its belief that the appellant had used a tax avoidance scheme to reduce the tax liability on the purchase of a residential property. 

Background 

A residential property in Harrogate was transferred to the appellant. Form TR1 dated 11 June 2008 stated: ‘The Transferor has received from the Transferee for the Property the sum of Five Hundred Forty-Two Thousand Five Hundred Pounds (£542,500).” The official copy entries stated: “The price stated to have been paid on 11 June 2008 was £542,000.”  

The appellant