We have commented previously on HMRC’s recent successes in the SDLT realm. A further two decisions – one relating to the application of mixed use SDLT rates and another on the availability of the relief from higher SDLT rates where the new property is a replacement for the taxpayer’s main residence – have continued this trend.
In Sexton v HMRC [2023] UKFTT 73 (TC) the taxpayers acquired a leasehold interest in a flat with a right under the lease to use a communal garden. Initially the taxpayers paid SDLT at residential property rates; however they later claimed a refund on the basis that the property was not in fact wholly...
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We have commented previously on HMRC’s recent successes in the SDLT realm. A further two decisions – one relating to the application of mixed use SDLT rates and another on the availability of the relief from higher SDLT rates where the new property is a replacement for the taxpayer’s main residence – have continued this trend.
In Sexton v HMRC [2023] UKFTT 73 (TC) the taxpayers acquired a leasehold interest in a flat with a right under the lease to use a communal garden. Initially the taxpayers paid SDLT at residential property rates; however they later claimed a refund on the basis that the property was not in fact wholly...
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