UT (Tax & Chancery) UT/2024/000092 - [2025] UKUT 00331 (TCC)
Upper Tribunal Tax and Chancery Chamber

UT (Tax & Chancery) UT/2024/000092 - [2025] UKUT 00331 (TCC)

Fecha: 23-Jun-2025

Conclusions

Conclusion

106.

For the reasons given above we allow the appeal in part. We set aside the FTT’s decision in so far as it relates to the ATED assessments and remake that decision so as to allow the Appellant’s appeal against the ATED assessments. The appeal against the SDLT assessment is dismissed.

JONATHAN CANNAN ANDREW SCOTT

UPPER TRIBUNAL JUDGES

RELEASE DATE: 06 October 2025