The specific anti-avoidance provisions of s. 75A (see ¶140-200ff) date originally from December 2006. They thus predate the General Anti-Abuse Rule (‘GAAR’) enacted in FA 2013, by almost seven years. SDLT is one of the taxes to which the GAAR applies (FA 2013, s. 206(3)(f)), in itself an admission, perhaps, that it is possible that s. 75A is not a provision that will comprehensively counteract ‘abusive’ arrangements and therefore needs a backstop in the way of the GAAR.

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