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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 treated as a single dwelling.
This appeal shows how fact-sensitive these decisions can be and how the subjective views of individual judges regarding the facts of the case can mean the difference between a defeat and a victory for the taxpayer.
You can read the decision here.

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BURLEY V HMRC [2025] UKFTT 989 (TC)

This appeal concerned the assignment by the taxpayer of his rights to the income from two film trading partnerships to an LLP of which he and his company were members. The company became entitled to the income which arose from the assignments, after the loan obligations taken out by the taxpayer...

L-L-O CONTRACTING LIMITED AND OTHERS V HMRC [2025] UKUT 00127 (TCC)

This was the hearing before the Upper Tribunal of the appellants' claims for overpayment relief from SDLT under paragraph 34 Schedule 10 FA 2003 in circumstances where the appellants had failed to claim Multiple Dwellings Relief ("MDR") in their return or in an amendment to their return, within 12 months...
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