THE COMMISSIONERS FOR HIS MAJESTY鈥橲 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 鈥� mixed use property 鈥� section 116 Finance Act 2003 鈥� suitable for use as a dwelling 鈥� relevance of covenant in a lease not to use the premises for residential purposes 鈥� relevance of planning law restrictions 鈥� whether the FTT failed to take into account all relevant factors 鈥� enquiry into land transaction return 鈥� HMRC concluding that not mixed use property 鈥� absence of any claim for multiple dwellings relief in the return or an amended return 鈥� whether HMRC should have given the benefit of multiple dwellings relief when closing the enquiry