TC09658 - [2025] UKFTT 01210 (TC)

On 30 June 2021, Mr Town purchased the Property, which included, what we refer to neutrally as Springwood House, Springwood Cottage and the Summerhouse.

On 7 July 2021, Mr Town filed his SDLT return which included a claim for MDR on the basis that the Property was comprised of two single dwellings.

Mr Town’s agent, Hallet & Co (the Agent), wrote to HMRC by letter dated 7 April 2022 requesting an amendment to Mr Town’s SDLT return and requesting a repayment of SDLT on the basis that the Property was in fact made up of three single dwellings.

HMRC gave effect to the requested amendment on 26 May 2022 and repaid Mr Town the resulting reduction in SDLT of £10,499.

However, on 11 January 2023 HMRC opened an enquiry into Mr Town’s amended SDLT return and on 27 October 2023 HMRC issued a closure notice concluding that the Property was made up of two single dwellings at the EDT. The closure notice amended Mr Town’s SDLT return accordingly making an additional £10,499 SDLT due.