Notable Cases
The members of Cannon Chambers relish representing their clients in the courts and tribunals and fighting their client’s corner whenever mediation is unsuccessful or a settlement is not possible. The following selection of their recent cases gives you a flavour of their work as advocates.
HARJONO & SANTOSO V HMRC TC/2023/00910
This decision concerned whether the purchase of a house, garden and a 1.5 acre paddock was of mixed residential and non-residential property for SDLT purposes because of the existence at the very point of completion of a commercial grazing lease over the paddock. Patrick Cannon represented the purchasers, and the...NEWSAND LIMITED V HMRC TC/2023/09861
This was an unsuccessful application by HMRC to strike-out the appellant company's appeal to the FTT over whether its purchase of a commercial building in Peterborough for £6.7m with consent for flats and where work had started on the day of completion, qualified for multiple dwellings relief ("MDR"). HMRC argued that...BONSU V HMRC TC/2022/11430
This was a mixed residential and non-residential use SDLT appeal involving the acquisition of a flat with the right to use a communal garden in which Patrick Cannon represented the appellant taxpayer. In deciding that the acquisition was wholly residential and therefore taxable at the rates in Table A of section...MARIE GUERLAIN-DESAI V HMRC TC/2022/13097
This was an application by HMRC for an extension of time in which to file their Statement of Case 64 days late. The FTT recited the familiar three-stage test in Martland [2018] UKUT 178 (TCC) for considering an application for an extension of time, i.e., (1) establish the length of the...BROSCH & BROSCH V HMRC TC/2020/01784
This was a decision on a "knock-out" point about whether discovery assessments were invalidated by the level of assumed disclosure given to HMRC by the appellants in relation to their use of Stamp Duty Land Tax avoidance schemes. The FTT held that while the information provided might have prompted the...Contact Us
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