SDLT Property Transaction Expert Witness UK

Stamp Duty Land Tax (SDLT) disputes requiring expert evidence typically involve HMRC challenging whether a transaction qualifies for multiple dwellings relief (MDR), mixed use classification of properties, GAAR application to SDLT planning arrangements, and the treatment of complex acquisition structures including sub-sales and alternative finance arrangements.

The tax expert witness provides independent technical opinion on the correct SDLT position, analysing the statutory provisions, HMRC guidance, and relevant tribunal decisions. SDLT planning cases often involve intricate questions about the nature of the transaction, the number of dwellings acquired, and whether arrangements fall within the General Anti-Abuse Rule.

With HMRC increasingly challenging SDLT planning through both direct enquiry and GAAR counteraction, expert evidence establishing the correct technical SDLT analysis is essential for both pre-tribunal negotiation and FTT proceedings.