THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS v DANIEL RIDGWAY [2024] UKUT 00036 (TCC)
Upper Tribunal Tax and Chancery decision of Judge Jonathan Cannan and Judge Vimal Tilakapala on 09 February 2024
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STAMP DUTY LAND TAX – mixed use property – section 116 Finance Act 2003 – suitable for use as a dwelling – relevance of covenant in a lease not to use the premises for residential purposes – relevance of planning law restrictions – whether the FTT failed to take into account all relevant factors – enquiry into land transaction return – HMRC concluding that not mixed use property – absence of any claim for multiple dwellings relief in the return or an amended return – whether HMRC should have given the benefit of multiple dwellings relief when closing the enquiry