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

UT (Tax & Chancery) Case Number: UT/2024/000092

Hearing venue: Rolls Building

London

EC4A 1NL

Judgment date: 06 October 2025

Stamp Duty Land Tax – high-value residential transaction – paragraph 5 Schedule 4A FA 2003 – whether chargeable interest acquired exclusively for the purpose of development or redevelopment and resale in the course of a property development trade – Annual Tax on Enveloped Dwellings – section 138 FA 2013 – whether single dwelling interest held exclusively for the purpose of developing and reselling the land in the course of a property development trade – whether FTT erred in law in identifying other purposes

Before

JUDGE JONATHAN CANNAN

JUDGE ANDREW SCOTT

Between

INVESTMENT AND SECURITIES TRUST LIMITED

Appellant

and

THE COMMISSIONERS FOR HIS MAJESTY’S

REVENUE AND CUSTOMS

Respondents

Representation:

For the Appellant: Laurent Sykes KC, instructed by Wilson Wright LLP

For the Respondent: Ben Elliott and Stacey Cranmore of counsel, instructed by the General Counsel and Solicitor for His Majesty’s Revenue and Customs

DECISION