In this appeal, I represented the taxpayers in their appeal to the Upper Tribunal which argued that their property purchases should have been classified as of mixed residential and non-residential land and so should have been liable to the lower rates of SDLT in Table B.’
We relied on HMRC’s published practice since 2003 that was only changed in 2019 as representing the correct legal interpretation of “residential property” but in the appeal, HMRC said that their practice had been a mistake and the Upper Tribunal agreed with them.
Read the full decision here.
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