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SW Broughall v HMRC

In SW Broughall v HMRC (TC01062 – 11 April) an individual (B) acquired both the leasehold and freehold interests in a property in June 2010. He submitted a land transaction return (SDLT1) showing both the freehold and leasehold title numbers and stating that the vendor of both titles was a bank (S).

HMRC issued SDLT5 certificates in respect of both purchases. However in August 2010 the Land Registry rejected the application for registration of change of ownership of the freehold on the grounds that the registered owner was a limited company (G) rather than S. B then submitted a replacement SDLT1 showing G as the vendor of the freehold. HMRC imposed a penalty on the grounds that the amended return had been delivered outside the statutory time limit. B appealed.

The First-tier Tribunal allowed the appeal observing that the...

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