Hemmant’s List members David Marks KC and Dr Pip Core acted for the taxpayer in the interesting recent stamp duty case of Special Situations Investing Group III, Inc. v Commissioner of State Revenue decided by Justice Bradley.
The case establishes the meaning of “group property” for taxpayers seeking exemption from stamp duty. When, as often happens, an item passes through several hands within a group, as part of a restructure, the case provides clarity about timing requirements, for that item to be considered as group property