UT (Tax & Chancery) UT-2024-000024 - [2025] UKUT 00156 (TCC)

Section 76 FA 2003 requires the purchaser in relation to “every notifiable transaction” to deliver a land transaction return to HMRC within 30 days of the effective date of the transaction:

“Section 76 – Duty to deliver land transaction return

(1)

In the case of every notifiable transaction the purchaser must deliver a return (a “land transaction return”) to the Inland Revenue before the end of the period of 30 days after the effective date of the transaction.

…

(3)

A land transaction return in respect of a chargeable transaction must -

(a)

include an assessment (a ‘self-assessment’) of the tax that, on the basis of the information contained in the return, is chargeable in respect of the transaction …”

For transactions prior to 12 March 2008, s77 did not specify that a notional land transaction under s75A was a notifiable transaction. However, for transactions, with an effective date on or after 12 March 2008, such as the Arrangements, section 77 (as amended by s94 Finance Act 2008) expressly provides that a notional transaction under s75A is a notifiable transaction:

“Section 77 – Notifiable transactions