MDR

Helen Coward

Sweet relief? Helen Coward and Amelia Roffey (Simmons & Simmons) examine recent guidance from the Upper Tribunal on SDLT overpayment claims.

Helen Coward

‘Overpayment relief is a statutory remedy of last resort.’ Helen Coward (Simmons & Simmons) examines when HMRC can refuse SDLT repayment claims – and when they cannot.

UK central management established Bermudan company’s residence: In Cogefin (Bermuda) Ltd and another v HMRC [2026] UKFTT 1108 (TC) (30 July), the FTT upheld HMRC’s discovery assessments, finding that the Bermuda-incorporated company was UK resident...

Property not two dwellings at time of acquisition for MDR purposes

Dwelling for SDLT purposes: In Shinebrook Ltd v HMRC [2026] UKFTT 602 (TC) (16 April), the FTT ruled that Multiple Dwellings Relief (MDR) from SDLT was not available in relation to the purchase of a former commercial property, on which planning...

Upper Tribunal denies SDLT overpayment relief

SDLT MDR denied where planning restriction existed.

SDLT pre-completion transactions and substantial performance: There are several complexities in G Goldsmith Ltd and another v HMRC [2024] UKFTT 927 (TC) (18 October) of interest to SDLT practitioners. It also shows some of the dangers which arise...

SDLT MDR claim denied: Shine Business Ltd v HMRC [2024] UKFTT 894 (TC) (7 October) is another in the long line of cases on the now-abolished SDLT multiple dwelling relief. Like all such appeals the decision is highly fact dependent. The FTT,...

MDR appeal allowed.

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