Mr & Mrs Michael v HMRC TC/2022/12710

Mr & Mrs Michael v HMRC TC/2022/12710 was an appeal involving a claim by the taxpayers that the property they had purchased was of mixed residential and non-residential land for stamp duty purposes due to the presence of a woodland of 3.5 acres at the back of their dwelling and its garden of half an acre.

The FTT did not accept the taxpayers’ evidence that the woodland did not provide any privacy or security for the half-acre garden and dwelling and so was not a part of the grounds of the dwelling and it applied mechanistically the nine principles derived from various SDLT cases on “grounds” as articulated by Judge Baldwin in Faiers v HMRC [2023] UKFTT 212 (TC) at [44] to decide that the entire property was residential and so subject to the rates of tax in Table A.

Mr & Mrs Michael Transfer Plan

To read the full decision, click 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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