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HYMAN, PENSFOLD AND GOODFELLOW V HMRC [2021]

In this appeal, Cannon Chambers represented the taxpayers in their appeal to the Upper Tribunal which argued that their property purchases should have been classified as of mixed residential and non-residential land and so should have been liable to the lower rates of SDLT in Table B.’

We relied on HMRC’s published practice since 2003 that was only changed in 2019 as representing the correct legal interpretation of “residential property” but in the appeal, HMRC said that their practice had been a mistake and the Upper Tribunal agreed with them.

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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