TC09658 - [2025] UKFTT 01210 (TC)

With the consent of the parties, the form of the hearing was video using the Teams video platform. A face to face hearing was not held at the Appellant’s request due to his caring responsibilities for his disabled daughter.

The documents to which we were referred are included in a document bundle of 253 pages and the Respondents’ skeleton argument of 10 pages.

Prior notice of the hearing had been published on the gov.uk website, with information about how representatives of the media or members of the public could apply to join the hearing remotely in order to observe the proceedings. As such, the hearing was held in public.

This appeal concerns Stamp Duty Land Tax (SDLT) and in particular whether the Appellant (Mr Town) is entitled to claim Multiple Dwellings Relief (MDR) on the acquisition of a property at Springwood House, Appledore Road, Kent TN30 7DH (the Property) for £1,512,500 on 30 June 2021 (the Purchase) calculated on the basis that it was comprised of three separate dwellings.

Mr Town asserts that the Property was comprised of three single dwellings on the 30 June 2021, the effective date of the transaction (EDT), and therefore qualified for MDR calculated on that basis. The Respondents (HMRC) assert that the Property was comprised of two single dwellings on the EDT and so qualified for MDR calculated on that basis.

Mr Town is appealing against a closure notice issued by HMRC on 27 October 2023 pursuant to paragraph 23 of Schedule 10 to the Finance Act 2003 (FA 2003) which amended Mr Town’s SDLT return in respect of the Property making £10,499 repayable by Mr Town to HMRC. This amount is the additional SDLT that HMRC assert is due from Mr Town as a consequence of HMRC calculating Mr Town’s claim for MDR on the Purchase, on the basis of it being comprised of two single dwellings rather than three single dwellings.