CDP Corporate & SDLT – HMRC Letters


Andy Wood

Andy is a practical, creative tax adviser who assists a variety of clients in achieving their personal and commercial objectives in the most tax efficient manner.

CDP Corporate & SDLT – HMRC Letters – Background

We have been involved with a number of clients, over several years, who have received letters from HMRC relating to their usage of SDLT schemes with the now defunct CDP Corporate.

CDP Corporate was involved in SDLT mitigation and operated for a number of years in the first part of this decade. They were based in Cheshire. As with many SDLT mitigation schemes, HMRC has challenged them aggressively and will not accept they provided the envisaged benefits…

CDP Corporate – SDLT Schemes

We have dealt with two specific schemes:

  • A structure purportedly designed by Patrick Cannon; and
  • A structure based on a forged opinion – in respect of which a Manchester lawyer was jailed. HMRC had asserted that two lots of SDLT were due and we have had a good level of success in setting these aside.

We have also dealt with a similar Company, Fiducia, offering similar SDLT schemes.

Our Services

At ETC Tax we have an experienced and specialist team who liaise with HMRC on your behalf. Due to the nature of the schemes and the stage at which HMRC are in their investigations in to the scheme, the potential results you could obtain with our help will differ.

If you have used one of these schemes, or any other scheme, have received a letter from HMRC or are just concerned about your scheme usage, then then please get in touch.

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