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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.

Marcus And Marcus Limited V HMRC [2022] UKFTT 145 (TC)

This is now the leading case in first tier tax tribunal listings on the approach of the tax tribunal to apportioning the purchase price to different buildings on a “just and reasonable” the basis for SDLT purposes. Patrick Cannon represented the taxpayer company and defeated HMRC’s attempt to apportion the...

Hyman and Goodfellow v HMRC [2022] EWCA Civ 185

This is the judgment of the Court of Appeal in which Patrick Cannon represented the appellants who sought to establish a workmanlike and coherent meaning of the phrase “grounds of a building” within the definition of “residential property” for SDLT purposes in section 116(1)(b) FA 2003. The Court of Appeal...

THE WAKELYN TRUST V HMRC [2022] TC/2019/01108/V

This was an appeal to the FTT over whether the release of a tenant’s reinstatement obligation contained in a lease formed deductible expenditure of the lessor for the purpose of section 38(1)(b) Taxation of Chargeable Gains Act 1992. Patrick Cannon represented the taxpayer trust in this appeal and the decision...

Victoria Carter & Peter Kennedy v HMRC [2021] UKUT 300 (TCC)

This was an appeal to the Upper Tribunal in which Patrick Cannon appeared for the taxpayers. The appeal concerned whether a hypothetical officer of HMRC could reasonably have been expected to have been aware that the self-assessment to tax was insufficient based on the information made available when the enquiry...

ROBERT DAVID GEORGE RACHEL CLAIRE GEORGE VS THE COMMISSIONERS FOR HMRC

This was a decision of Judge Poon on an appeal for a claim for multiple dwellings relief that was heard before the Upper Tribunal's decision in Fiander and Brower but delayed by the judge to take account of the Upper Tribunal's decision. The decision has some detailed remarks on the...

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...
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