Notable Cases
The members of Cannon Chambers relish representing their clients in the courts and tribunals and fighting their client’s corner whenever mediation is unsuccessful or a settlement is not possible. The following selection of their recent cases gives you a flavour of their work as advocates.
ANDREI TRETYAKOV V HMRC TC/2023/16164
This decision concerned an SDLT mixed-use appeal, i.e., whether the property in question was of mixed residential and non-residential use. The additional SDLT if the property was wholly residential was £484,250. It might be thought that genuine commercial use of a part of a building where the other parts were...THE WOOL HOUSE LIMITED V HMRC TC/2022/11576 and 2023/00414
In this appeal to the FTT, HMRC sought recovery of an SDLT refund paid to the taxpayer and received by it around the same time as the issue of the closure notice refusing the claim and asking for the refund to be repaid with interest. The core question for the...ALEXANDER CLARK AND REBECCA CLARK V HMRC TC/2023/00127
In this appeal about whether there were two separate dwellings at the property for the purpose of Multiple Dwellings Relief, the First-tier Tax Tribunal said that insufficient degrees of separation and privacy and security together with the status of the common utilities meant that the two dwellings could not each be...SUTERWALLA V HMRC [2024] UKUT 00188 (TCC)
This was HMRC's unsuccessful appeal to the Upper Tribunal against the FTT's decision that a paddock was not part of the grounds of a dwelling house for SDLT mixed-use purposes. In relation to HMRC's challenge, the UT said: "41. Mr Cannon submitted that HMRC’s challenges in this ground were ‘island...DAVIS and GUILBERT V HMRC
This was a successful appeal by the taxpayers involving an uninhabitable dwelling they had purchased in London SW3 in 2020. They said that the dwelling was uninhabitable because of several defects which rendered the property potentially dangerous but HMRC did not accept that the property was uninhabitable. The Tribunal carefully reviewed...Contact Us
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