HMRC v DV3 Regent Street Ltd – FTC/48/2011
| Jurisdiction | UK Non-devolved |
| Judge | MR JUSTICE HENDERSON |
| Judgment Date | 19 July 2012 |
| Neutral Citation | [2012] UKUT 399 (TCC) |
| Respondent | DV3 RS LIMITED PARTNERSHIP |
| Appellant | REVENUE AND CUSTOMS |
| Court | Upper Tribunal (Tax and Chancery Chamber) |
| Appeal Number | FTC/48/2011 |
[2012] UKUT 399 (TCC)
Appeal number FTC/48/2011
SDLT – sub-sale – acquisition by partnership – effect of sections 45 and 44
on paragraph 10 of Schedule 15 FA 2003 – appeal dismissed
UPPER TRIBUNAL (TAX AND CHANCERY CHAMBER)
THE COMMISSIONERS FOR HER MAJESTY’S
REVENUE AND CUSTOMS Appellants
- and -
DV3 RS LIMITED PARTNERSHIP Respondent
TRIBUNAL: MR JUSTICE HENDERSON
Sitting in public at the Rolls Building, London EC4A 1NL on 18 and 19 July 2012
Mr Malcolm Gammie QC, instructed by the General Counsel and Solicitor to HMRC,
for the Appellants
Mr Roger Thomas, instructed by Olswang LLP, for the Respondent
2
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1 cases
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The Commissioners for HM Revenue and Customs v Dv3 RS Ltd Partnership
...on the facts, and that Parliament would not consciously have intended the result for which the Company argued. His decision is at [2012] UKUT 399 (TCC) and is available on BAILII. The question for us is: was he right? 2 With the permission of the Upper Tribunal HMRC appeal. Their case was p......