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S and J Holding v HMRC

In S and J Holding v HMRC [2024] UKFTT 337 (TC) (19 April 2024) the First-tier Tribunal (FTT) dismissed the taxpayers’ appeal agreeing with HMRC that the property and all 41 acres of land acquired with it (of which 24 acres were fields) constituted residential property and therefore attracted residential rates of SDLT. 

The FTT considered an appeal against a closure notice charging the appellants to SDLT on the basis that an acquisition of property (which was a dwelling) and land was wholly residential for SDLT purposes. The taxpayer argued unsuccessfully that several of the fields included in the property did not constitute grounds of the dwelling for the purposes of FA 2003 s 116(1)(b) and were instead non-residential property so that the lower non-residential rate of SDLT should have applied to the acquisition. HMRC successfully contended that all of the land including the fields constituted...

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