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Hopscotch Ltd v HMRC

In Hopscotch Ltd v HMRC [2020] UKUT 294 (TCC) (29 October 2020) the Upper Tribunal (UT) found that the First-tier Tribunal (FTT) had not erred in law in concluding that no trade was carried on for the purpose of property development relief from the annual tax on enveloped dwellings (ATED). This meant that the property did not qualify for relief from ATED.

Hopscotch had purchased a residential property in 1993 as an investment. The property was originally occupied by members of staff until its use declined and in 2011 Hopscotch decided to sell it. It was unable to find a buyer and following the advice of its estate agent in 2016 Hopscotch undertook a vast redevelopment programme in the hope of making the property more valuable and marketable. When ATED was introduced Hopscotch paid ATED in respect of the property. From 2017 Hopscotch claimed relief...

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