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J Harjono and another v HMRC

In J Harjono and another v HMRC [2024] UKFTT 228 (TC) (18 March 2024) the FTT dismissed the taxpayers’ appeal against a closure notice issued by HMRC finding that the property in dispute was entirely residential and that the mixed-use rates of SDLT did not apply. 

The taxpayers purchased a property consisting of a residential barn conversion and three acres of land. Half of the land consisted of a fenced paddock. The paddock was contiguous with the garden and had two gates one from the garden and one on to the road. The taxpayers entered into an agreement with a friend to allow her to graze her horse on the paddock for a fixed term of six months and for a monthly fee of £50. The agreement was signed by both parties before the completion of the purchase but was undated until after completion when on the...

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