SDLT

UT denies SDLT group relief because of tax avoidance main purpose.

John Shallcross (Blake Morgan) sets out what can be learnt from a recent decision where the FTT held HMRC could refuse to give effect to an overpayment relief claim for SDLT involving MDR for mixed property.

Klara Kronbergs

Edward Reed

In this month’s review, Edward Reed and Klara Kronbergs (Macfarlanes) consider some of the more nuanced aspects of the non-dom reforms, as well as some key tribunal decisions affecting private clients.

SDLT assessment and closure notice: The Wool House Ltd v HMRC [2024] UKFTT 997 (TC) (30 October) is quite an administrative tangle. The taxpayer paid SDLT on the normal single-property basis but then put in an overpayment relief claim, on the basis...

SDLT MDR was available:T Yeomans v HMRC [2024] UKFTT 955 (TC) (24 October) is another SDLT multiple dwellings relief case but unlike some other cases, where the phrase ‘clutching at straws’ comes to mind, this one was clearly...

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 overpayment claim refused.

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,...