In Hopscotch v HMRC [2019] UKFTT 288 (2 May 2019) the FTT found that a property first held as an investment and then redeveloped and sold had not been owned for the purpose of being developed and sold so that it did not qualify for relief from the annual tax on enveloped dwellings (ATED).
Hopscotch had purchased a residential property in 1993. It was originally occupied by members of staff until its use declined and Hopscotch decided to sell it. However unable to find a buyer and following the advice of its estate agent Hopscotch had undertaken a vast redevelopment programme in the hope of making the property both more valuable and marketable.
When the ATED regime was introduced by FA 2013 Hopscotch submitted ATED returns for the first three ATED chargeable periods on the value of the property (£13.5m) without any relief. However ...
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