Troy Homes v HMRC [2020]

Troy Homes v HMRC [2020]

Patrick Cannon successfully persuaded the First-tier Tax Tribunal that HMRC had failed to “properly address” their enquiry notices into the taxpayer companies’ SDLT returns which claimed multiple dwellings relief with the result that the enquiries were not begun within the nine month time limit and the additional tax charged by the closure notices was cancelled.

The appeal also drew attention to a defect in the way in which the SDLT return form captures the correct address for service of an enquiry notice on the taxpayer. The decision can be read here.

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