JPHLAW Business Lawyers’ Post

Taxpayer wins SDLT dispute over manor house used as pub The buyer of a GBP1.8-million manor house has persuaded the First-tier Tax Tribunal (FTT) that the property was not wholly residential and so entitled to mixed-use relief from stamp duty land tax (SLDT). The applicant successfully argued that the property was being used as a hotel, inn or similar establishment (HISE) at the effective date of the transaction and that part of the property was leased out to a farmer for grazing. This consequently saved an additional SDLT bill of GBP47,750. However, the FTT noted it had allowed the appeal on the ‘finest of margins’, partly influenced by the COVID-19 restrictions in place at the relevant times (Hurst v HMRC, 2024 UKFTT 540 TC).

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