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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.

SMITH HOMES 9 LTD V REVENUE AND CUSTOMS COMMISSIONERS [2021]

This was an unsuccessful application by HMRC to strike out the taxpayer’s appeal against a closure notice refusing overpayment relief for multiple dwellings relief on a claim by the taxpayer which was made more than 12 months after the filing date of the SDLT return under para 34 Sch 10…

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…

FIANDER AND BROWER V HMRC [2021]

This was the appeal to the Upper Tribunal in the first appeal case relating to multiple dwellings relief from SDLT. The appeal raised the awkward issue of a disagreement between the appellants and the judge at first instance over what one of the appellants had said when Cannon Chambers questioned…

BENTLEY V HMRC [2021]

This decision is a practical example of the FTT judge reconsidering his decision (which had already been published) to reduce the appellant’s follower notice penalties to 24% of the denied tax advantage. The judge reviewed his own decision under rule 41 of the FTT rules and remade it to restore the…

BRANDBROS LIMITED V HMRC [2021]

This decision addresses the effect for SDLT purposes of the grant of a commercial lease over the garage of a residential property by the purchaser on the day of completion and whether that had the effect of causing the property purchased to be treated as mixed-use. The FTT held in…

MR AND MRS MULLANE V HMRC [2021]

This case was about multiple-dwellings relief and it contains a number of judicial comments favourable to taxpayers claiming MDR in the context of an annexe that is joined to the main dwelling. However, the suggestion that an intention to let the annexe out is necessary to claim MDR is quite…

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