Making Tax Digital for Corporation Tax

27 Nov 2020

HMRC response:

I am able to confirm that partial relief would not be available in the circumstances outlined.

We consider the decision in the Pollen case relates solely to transactions involving a charity as a joint purchaser, this is based on the appeal being allowed on the ‚ narrow ground that para 1 Schedule 8 should be interpreted‚ in the way set out in the judgement. We have specifically legislated for those scenarios in para 3A Schedule 8 FA03. As a result, for all other reliefs to be available, all of the purchasers must meet the relevant conditions.‚