Troy Homes Ltd and another v HMRC

In Troy Homes Ltd and another v HMRC [2020] UKFTT 174 (TC) (13 May 2020) the FTT held that HMRC had not properly served enquiry notices on two companies within the statutory enquiry period. FA 2003 s 84 requires HMRC to serve enquiry notices on the taxpayer's principal place of business. In this case the taxpayer had used their registered address on the SDLT return and HMRC had served the enquiry notices on that address.

Troy Homes Ltd and Troy Homes (Inland) Ltd (the purchasers) had each acquired land and submitted land transactions returns. HMRC opened enquiries into both returns on the basis that multiple dwellings relief (MDR) was not available. HMRC served enquiry notices on the purchasers at the address provided on the SDLT return and issued closure notices on 8 January 2018. The purchasers appealed on the basis that the...