Sergeant & Sims on Stamp Taxes

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Sergeant & Sims on Stamp Taxes is referred to in preference to any other work in correspondence with the Stamp Office and is the usual authority to be cited in courts. Sergeant and Sims on Stamp Duties is the most comprehensive, up-to-date and authoritative guide to stamp duties and stamp duty reserve tax available. The work provides practitioners with guidance on the methods to employ in order to ensure that they take advantage of every tax-saving opportunity and do not incur penalties for late stamping. The work comprises all current relevant legislation, whilst the detailed commentary provides expert guidance particularly on the more complex areas. It includes coverage of the new stamp taxes regime established under the Finance Act 2003 along with text of relevant statements of practice, interpretations, press releases, extracts from Hansard, examples of Stamp Office forms and useful contact details.

Issue 46, August 2023

Issue 46 updates the publication to reflect developments since Issue 45 (February 2023).
So far as material and in no particular order, the relevant changes include:


Division A—Commentary: Securities
  • The consultation on specific proposals to replace stamp duty and SDRT with a new single tax on securities.

  • The consultation on making changes to the stamp duty and SDRT legislation to accommodate transactions in a new type of investment fund, the reserved investor fund, an unauthorised contractual scheme.

  • Division AA—Commentary: Land
  • HMRC’s new guidance on chattels.

  • Four First-tier Tribunal decisions in Suterwalla (on mixed-use), Mudan (on derelict dwellings), Sexton (on a communal garden), and Fairers (on the meaning of ‘grounds’).

  • The Upper Tribunal decision in The How (on the meaning of ‘grounds’).

  • A decision of the GAAR Advisory Panel on a specific SDLT avoidance scheme involving a sub-sale and an annuity, variations of which have already been the subject of unsuccessful SDLT appeals.

  • Two procedural decisions in Hitchins (on a closure notice direction for an income tax enquiry) and Marie Guerlain-Desai (on bringing a late SDLT appeal).

  • The consultation on making significant changes to the LBTT additional dwelling supplement legislation following a number of unsuccessful appeals against Revenue Scotland’s decision to impose the charge on sympathetic facts.

  • The consultation on proposed legislation to provide a relief from LBTT for qualifying non-residential transactions within a designated Green Freeport tax site.

  • Division AB—Commentary: ATED
  • General updating.

  • Division G—Address and contact numbers
  • General updating.

  • Division H—Recent developments
  • General updating.

  • For subscriptions and filing enquiries, see the customer queries information, which is printed at the end of the Filing Instructions that follow this page.
    Once it has been circulated to all users of Sergeant and Sims on Stamp Duties these pages may be filed at the front of the Binder.


    Sean Randall  Author