Ladson Preston Ltd and another v HMRC

In Ladson Preston Ltd and another v HMRC [2021] UKFTT 251 (TC) (7 July 2021) the First-tier Tribunal (FTT) held that multiple dwellings relief (MDR) did not apply to either an acquisition of land with planning permission or an acquisition of commercial buildings with planning permission where the buyer had dug bore holes. These two cases have been designated as lead appeals with two groups of appeals stayed behind them.

Both Ladson Preston Ltd (Ladson) and AKA Developments Greenfield Ltd (AKA) acquired property over which planning permission had been granted for the construction of multiple dwellings. At the effective date of each transaction no dwellings had been constructed. Both Ladson and AKA argued that the existence of planning permission was sufficient to satisfy the statutory language of FA 2003 Sch 6B para 7(2)(b). This provides that a building counts as a dwelling for the purposes of MDR if it...

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