FTT decision on SDLT upheld: C Halstead v HMRC [2025] UKUT 22 (TCC) (15 January) is a decision of the UT refusing an application by the taxpayer to appeal against a decision of the FTT. We are now starting to see publication of the decisions in several of these applications and here as in other instances the detailed reasoning for the refusal of the application is almost as extensive as the substantive decision would have been had permission been granted.
The taxpayer was arguing that he was entitled to SDLT relief as he was a member of the armed forces. His appeal was rejected by the FTT on the basis that the relief was clearly designed for the land and buildings occupied by a forces institution and not to individual members of the armed forces. The UT confirmed that this was the correct reading. There are also some...
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FTT decision on SDLT upheld: C Halstead v HMRC [2025] UKUT 22 (TCC) (15 January) is a decision of the UT refusing an application by the taxpayer to appeal against a decision of the FTT. We are now starting to see publication of the decisions in several of these applications and here as in other instances the detailed reasoning for the refusal of the application is almost as extensive as the substantive decision would have been had permission been granted.
The taxpayer was arguing that he was entitled to SDLT relief as he was a member of the armed forces. His appeal was rejected by the FTT on the basis that the relief was clearly designed for the land and buildings occupied by a forces institution and not to individual members of the armed forces. The UT confirmed that this was the correct reading. There are also some...
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