In L-L-O Contracting Ltd and others v HMRC [2025] UKUT 127 (TCC) (14 April) the Upper Tribunal (UT) dismissed the companies’ appeals against the FTT’s decision to dismiss appeals against HMRC’s decision not to allow claims to SDLT overpayment relief. The companies had not claimed multiple dwellings relief (MDR) in their SDLT returns and having missed the time limit for making the claims sought to obtain the relief by way of overpayment relief claims under FA 2003 Sch 10 para 34.
The dispute concerned land transactions by ten separate companies between 2016 and 2019. Each company made an overpayment relief claim under Sch 10 para 34 on the basis that MDR should apply. HMRC refused the claims considering that they were not liable to give effect to them as they fell within Case A in FA 2003 Sch 10 para...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
In L-L-O Contracting Ltd and others v HMRC [2025] UKUT 127 (TCC) (14 April) the Upper Tribunal (UT) dismissed the companies’ appeals against the FTT’s decision to dismiss appeals against HMRC’s decision not to allow claims to SDLT overpayment relief. The companies had not claimed multiple dwellings relief (MDR) in their SDLT returns and having missed the time limit for making the claims sought to obtain the relief by way of overpayment relief claims under FA 2003 Sch 10 para 34.
The dispute concerned land transactions by ten separate companies between 2016 and 2019. Each company made an overpayment relief claim under Sch 10 para 34 on the basis that MDR should apply. HMRC refused the claims considering that they were not liable to give effect to them as they fell within Case A in FA 2003 Sch 10 para...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
