HMRC v D Ridgway

In HMRC v D Ridgway [2024] UKUT 36 (TCC) (9 February 2024) the UT allowed HMRC’s appeal against a decision of the FTT which had allowed SDLT multiple dwellings relief.

The taxpayer bought a property which comprised two separate registered titles. The first was a semi-detached house and gardens the second was adjoining land with a building called the Old Summer House which had originally been used as a garage and later as an artist’s studio. His solicitor advised him that if the Old Summer House were in commercial use at the time of completion he would be able to apply the lower rate of SDLT for properties with mixed use. Two weeks before completion the taxpayer arranged for the vendors to grant a six-month commercial lease to a photography business to enable him to claim mixed use relief. The lease contained a covenant that the...

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