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DANIELLE AND EMMA SEXTON V HMRC TC/2022/00160

Patrick Cannon represented the taxpayers in this appeal relating to the purchase of a long lease of a flat which came with an easement allowing the use of a communal garden in a square adjacent to the building housing the flat.

The tribunal held that this was not a purchase of mixed-use land and the decision contains a helpful analysis of the meaning of “the main subject matter” of a land transaction in section 43(6) FA 2003

You can read the full 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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