PAUL AND JANE WILKINSON V HMRC [2021]

In this appeal, I represented the taxpayers Paul and Jane Wilkinson in their appeal against HMRC’s refusal to allow a claim for multiple-dwellings relief from SDLT. The decision contains detailed comment and analysis from Judge Bowler on the application of the definition of “dwelling” for MDR to the detailed facts of this case.

Read the full decision here.

THE WOOL HOUSE LIMITED V HMRC TC/2022/11576 and 2023/00414

In this appeal to the FTT, HMRC sought recovery of an SDLT refund paid to the taxpayer and received by it around the same time as the issue of the closure notice refusing the claim and asking for the refund to be repaid with interest. The core question for the...

ALEXANDER CLARK AND REBECCA CLARK V HMRC TC/2023/00127

In this appeal about whether there were two separate dwellings at the property for the purpose of Multiple Dwellings Relief, the First-tier Tax Tribunal said that insufficient degrees of separation and privacy and security together with the status of the common utilities meant that the two dwellings could not each be...

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