Planning condition did not make residential property non-residential
In B Patel v HMRC [2025] UKFTT 373 (TC) (27 March) the First-tier Tribunal (FTT) dismissed the taxpayer’s appeal against an assessment for SDLT on the purchase of a partly completed development with planning permission to convert two properties into one house. The FTT held that the properties were in the process of being constructed or adapted for use as a dwelling so that the residential rate of SDLT applied.
The taxpayer purchased two properties which were being converted into a single five-bedroom house. At the effective date of the purchase it was effectively a building site; new roofs were under construction and the walls were bare concrete or brick. The planning permission for the conversion included a condition that prevented occupation of the converted house until a second nearby development of five residential units was completed and ready...
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Planning condition did not make residential property non-residential
In B Patel v HMRC [2025] UKFTT 373 (TC) (27 March) the First-tier Tribunal (FTT) dismissed the taxpayer’s appeal against an assessment for SDLT on the purchase of a partly completed development with planning permission to convert two properties into one house. The FTT held that the properties were in the process of being constructed or adapted for use as a dwelling so that the residential rate of SDLT applied.
The taxpayer purchased two properties which were being converted into a single five-bedroom house. At the effective date of the purchase it was effectively a building site; new roofs were under construction and the walls were bare concrete or brick. The planning permission for the conversion included a condition that prevented occupation of the converted house until a second nearby development of five residential units was completed and ready...
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