ABSTRACT
This chapter deals with the ruling which can be sought, both pre-transaction and post-transaction, from Her Majesty's Revenue and Customs (HMRC), together with the changes brought in sequentially by the Finance Acts 2004, 2005, 2006 and 2007. Code of Practice 10 (COP 10) details how HMRC offers information and advice to taxpayers to help them understand obligations, so that they can get their tax affairs correct and pay tax on time. COP 10 rulings will, in many cases, automatically trigger an enquiry into the Land Transaction Return (LTR) by HRMC. Stamp duty land tax (SDLT) legislation itself is based on anti-avoidance. Anti-avoidance generally has been a driving force in taxation legislation over the last decade. This has led to most taxes, such as income tax, corporation tax, and value added tax (VAT) being subject to the introduction of general anti-avoidance legislation commonly referred to as general anti-avoidance regulation (GAAR).
