Arrangements involving main residence not excepted from higher rate SDLT
In A Sajedi and others v HMRC [2025] UKFTT 297 (TC) (6 March) the FTT upheld closure notices denying relief from SDLT charged at the higher rate for purchases of additional dwellings. The FTT found that the purchased dwellings were not a replacement for the purchaser’s only or main residence because the purchaser had not disposed of a major interest in that residence.
This case concerned the application of FA 2003 Sch 4ZA para 3 to arrangements involving the purchase of a new dwelling and subsequently the purported disposal of an interest in the purchaser’s previous main residence (the original dwelling). In one case the purchaser transferred a 1% interest in the original dwelling to his partner on severance of a joint tenancy. In the other case the purchaser declared a trust over the original dwelling for...
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Arrangements involving main residence not excepted from higher rate SDLT
In A Sajedi and others v HMRC [2025] UKFTT 297 (TC) (6 March) the FTT upheld closure notices denying relief from SDLT charged at the higher rate for purchases of additional dwellings. The FTT found that the purchased dwellings were not a replacement for the purchaser’s only or main residence because the purchaser had not disposed of a major interest in that residence.
This case concerned the application of FA 2003 Sch 4ZA para 3 to arrangements involving the purchase of a new dwelling and subsequently the purported disposal of an interest in the purchaser’s previous main residence (the original dwelling). In one case the purchaser transferred a 1% interest in the original dwelling to his partner on severance of a joint tenancy. In the other case the purchaser declared a trust over the original dwelling for...
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