WATERSIDE ESCAPES LTD V HMRC [2020]

This appeal, in which Patrick Cannon appeared for the taxpayer company, contains a detailed analysis of the scope of the 15% SDLT charge under Schedule 4A FA 2003 and whether there was ‘representative occupation” by a director and also of the sum of the lower proportions calculation in para 20 Schedule 15 FA 2003 and the attribution of control to associates within section 451 CTA 2010 in a purchase by a company from an LLP whose partners were connected with the purchasing company.

Read the full decision here.

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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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