[2024] UKUT 00301 (LC)

This is an appeal against a determination of the Commissioners for His Majesty’s Revenue and Customs (‘HMRC’) in respect of the freehold value of 12 Chester Square, London, SW1W 9HH (‘the appeal property’).

The appeal was transferred to the Tribunal by an Order of Judge Bailey of the First-tier Tribunal (Tax Chamber) dated 2 August 2023 (ref TC/2023/00236). It concerns the valuation of the appeal property on 1 April 2017.

HMRC determined that the value of the appeal property fell into the £10-20 million bracket for the purposes of Annual Tax on Enveloped Dwellings (‘ATED’).

The appellant is Chifley Holdings Limited, a company based in the British Virgin Islands. It says that the value of the appeal property was £9,325,000, thus falling within the sub-£10 million bracket.