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LADSON PRESTON LTD AND AKA DEVELOPMENTS GREENVIEW LTD V HMRC [2021]

These two appeals related to claims for multiple dwellings relief from SDLT where the dwellings had not yet been built at the effective date of the transaction and the relevance of the prior grant of planning permission for the construction of the dwellings and also where construction work had begun on the effective date of the transactions. These decisions emphasise that developers should seek to substantially perform the purchase contract ahead of completion under a contract that obliges them to build the dwellings so that para 7(5) Sch 6B FA 2003 will deem the unbuilt dwellings to be in existence for the purposes of the relief.

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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