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Sequence Care Group Holdings v HMRC

In Sequence Care Group Holdings v HMRC [2018] UKFTT 243 (30 April 2018) the FTT confirmed that no relief from the stamp duty land tax (SDLT) higher rate (FA 2003 Sch 4A) applies to the acquisition by a company of a residential property to be used as a care home.

Sequence provides specialist residential and care services entailing rehabilitative support for adults with learning disabilities mental health needs etc. It had completed the purchase of a five bedroom house for a price of £560 000 in February 2015; and filed an electronic return calculating the SDLT due at £18 000. It had in October 2014 obtained planning consent for alterations and change of use to a care home. HMRC considered that the 15% SDLT rate applied.

It was accepted that the requirements in Sch 4A paras 2 and 3 were satisfied so that the higher rate...

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