James and Charlotte Averdieck V HMRC TC/2022/02324

This is the first appeal about mixed-use residential and non-residential property for SDLT in the wake of the Court of Appeal’s decision on the meaning of “grounds of a dwelling” in Hyman and Goodfellow v HMRC [2022] EWCA Civ 185. Patrick Cannon represented the taxpayers who sought to establish that part of a busy public road within the boundary of their residential property served no functional purpose for the property and so should not be regarded as the grounds of the dwelling.

You can read the full decision here

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...

CHARLIE JOHNSON V HMRC TC/2024/00254

This was a successful appeal by the taxpayer about whether multiple dwellings relief ("MDR") from SDLT applied to his purchase of a residential property with a self-contained annex. In a carefully structured and considered decision the FTT reviewed the evidence thoroughly and held that HMRC's objections concerning the interconnecting doors and shared...

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