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Tax law [2026] UKFTT 615

Madsen v Revenue and Customs (SDLT avoidance; grant of call option prior to completion; Finance Act 2003, s.45 (as it stood in 2011); discovery assessment; knowledge of hypothetical officer)

Madsen v Revenue and Customs (SDLT avoidance; grant of call option prior to completion; Finance Act 2003, s.45 (as it stood in 2011); discovery assessment; knowledge of hypothetical officer) [2026] UKFTT 615 (TC) (21 April 2026)

The Tribunal allowed an SDLT appeal, holding that a 31 January 2012 disclosure letter was received and gave HMRC enough information to bar a discovery assessment.

  • Stamp duty land tax (sdlt)
  • Discovery assessment
  • Disclosure requirements
  • Finance act 2003
  • Sdlt avoidance schemes
  • Stamp-duty-land-tax
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Tax law [2026] UKFTT 615 (TC)

Madsen v Revenue and Customs (SDLT avoidance; grant of call option prior to completion; Finance Act 2003, s.45 (as it stood in 2011); discovery assessment; knowledge of hypothetical officer)

Madsen v Revenue and Customs (SDLT avoidance; grant of call option prior to completion; Finance Act 2003, s.45 (as it stood in 2011); discovery assessment; knowledge of hypothetical officer) [2026] UKFTT 615 (TC) (21 April 2026)

The Tribunal allowed an SDLT appeal, holding that a 31 January 2012 disclosure letter, together with the return, meant the discovery assessment was invalid.

  • Stamp duty land tax (sdlt)
  • Discovery assessment
  • Disclosure requirements
  • Finance act 2003
  • Tax avoidance schemes
  • Stamp-duty-land-tax
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Tax law [2026] UKFTT 265 (TC)

Wood & Anor v Revenue and Customs (Stamp Duty Land Tax - rate of SDLT applicable - whether Table A or Table B - whether the house and land included land that was not residential property - whether all of land was, or formed part of, grounds of house - Finance Act 2003, ss 55, 116)

Wood & Anor v Revenue and Customs (Stamp Duty Land Tax - rate of SDLT applicable - whether Table A or Table B - whether the house and land included land that was not residential property - whether all of land was, or formed part of, grounds of house - Finance Act 2003, ss 55, 116) [2026] UKFTT 265 (TC) (20 February 2026)

The First-tier Tribunal allowed an SDLT appeal, holding that a public towpath did not form part of the house’s grounds, so mixed-use rates applied.

  • Stamp duty land tax
  • Residential property definition
  • Mixed-use property
  • Finance act 2003
  • Stamp-duty-land-tax
  • Mixed-use-property
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Tax law [2026] UKFTT 265

Wood & Anor v Revenue and Customs (Stamp Duty Land Tax - rate of SDLT applicable - whether Table A or Table B - whether the house and land included land that was not residential property - whether all of land was, or formed part of, grounds of house - Finance Act 2003, ss 55, 116)

Wood & Anor v Revenue and Customs (Stamp Duty Land Tax - rate of SDLT applicable - whether Table A or Table B - whether the house and land included land that was not residential property - whether all of land was, or formed part of, grounds of house - Finance Act 2003, ss 55, 116) [2026] UKFTT 265 (TC) (20 February 2026)

The tribunal allowed an SDLT appeal, holding that a busy public towpath did not form part of the house’s grounds, so the property was mixed use.

  • Stamp duty land tax
  • Residential vs non-residential property
  • Finance act 2003
  • Sdlt returns and amendments
  • Stamp-duty-land-tax
  • Mixed-use-property
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Tax law [2025] UKFTT 1067

Berrell & Anor v Revenue and Customs (Stamp duty land tax - multiple dwellings relief - whether open to Tribunal to envisage terms of occupancy)

Berrell & Anor v Revenue and Customs (Stamp duty land tax - multiple dwellings relief - whether open to Tribunal to envisage terms of occupancy) [2025] UKFTT 1067 (TC) (04 September 2025)

The Tribunal allowed an SDLT multiple dwellings relief appeal, holding that a house and annexe were each suitable for use as a single dwelling at completion.

  • Stamp duty land tax
  • Multiple dwellings relief
  • Finance act 2003
  • Property law
  • Statutory interpretation
  • Stamp-duty-land-tax
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Tax law [2025] UKFTT 416

Candy v Revenue and Customs (SDLT - whether a claim for overpayment relief can be brought)

Candy v Revenue and Customs (SDLT - whether a claim for overpayment relief can be brought) [2025] UKFTT 416 (TC) (10 April 2025)

The tribunal held that Schedule 10 paragraph 34 could be used as a back-stop to recover SDLT even though a repayment claim under section 44(9) was out of time.

  • Stamp duty land tax
  • Overpayment relief
  • Statutory interpretation
  • Finance act 2003
  • Stamp-duty-land-tax
  • Overpayment-relief
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Tax law [2025] UKFTT 399

Gabra & Anor v Revenue and Customs (STAMP DUTY LAND TAX - Multiple Dwellings Relief (FA 2003 Sch 6B) - Entitlement to claim relief - Suitable for use as a single dwelling - The process of being adapted)

Gabra & Anor v Revenue and Customs (STAMP DUTY LAND TAX - Multiple Dwellings Relief (FA 2003 Sch 6B) - Entitlement to claim relief - Suitable for use as a single dwelling - The process of being adapted) [2025] UKFTT 399 (TC) (04 April 2025)

The First-tier Tribunal held that the Annexe at The Willows was not a separate dwelling for SDLT Multiple Dwellings Relief, and dismissed the appeal.

  • Stamp duty land tax
  • Multiple dwellings relief
  • Finance act 2003
  • Definition of dwelling
  • Entitlement to tax relief
  • Stamp-duty-land-tax
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Tax law [2025] UKFTT 399 (TC)

Gabra & Anor v Revenue and Customs (STAMP DUTY LAND TAX - Multiple Dwellings Relief (FA 2003 Sch 6B) - Entitlement to claim relief - Suitable for use as a single dwelling - The process of being adapted)

Gabra & Anor v Revenue and Customs (STAMP DUTY LAND TAX - Multiple Dwellings Relief (FA 2003 Sch 6B) - Entitlement to claim relief - Suitable for use as a single dwelling - The process of being adapted) [2025] UKFTT 399 (TC) (04 April 2025)

The tribunal dismissed an SDLT appeal, holding that an annexe was neither suitable for use as a single dwelling nor in the process of being adapted at completion.

  • Stamp duty land tax
  • Multiple dwellings relief
  • Finance act 2003
  • Schedule 6b
  • Definition of dwelling
  • Effective date of transaction
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Tax law [2025] UKFTT 55

Robinson & Anor v Revenue and Customs (TAMP DUTY LAND TAX - HMRC application to strike out)

Robinson & Anor v Revenue and Customs (TAMP DUTY LAND TAX - HMRC application to strike out) [2025] UKFTT 55 (TC) (03 January 2025)

The First-tier Tribunal struck out a stamp duty land tax appeal over a marketed subsale and annuity scheme, holding it had no realistic prospect of success.

  • Stamp duty land tax
  • Tax avoidance
  • Pre-completion transaction relief
  • Anti-avoidance provisions
  • Finance act 2003
  • Stamp-duty-land-tax
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Tax law [2024] UKFTT 997 (TC)

The Wool House Ltd v Revenue and Customs (Stamp Duty Land Tax, recovery of invalid MDR claim paid on provisional basis)

The Wool House Ltd v Revenue and Customs (Stamp Duty Land Tax, recovery of invalid MDR claim paid on provisional basis) [2024] UKFTT 997 (TC) (30 October 2024)

The tribunal held that HMRC’s assessment to recover an overpaid SDLT refund was valid, and dismissed the appeal. The refund had been paid provisionally.

  • Stamp duty land tax
  • Multiple dwellings relief
  • Overpayment relief
  • Closure notice
  • Assessment timing
  • Finance act 2003
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United Kingdom decisions are organised by court, judge, legal area and indexed issue so a practitioner can move from a proposition to a citable authority with the surrounding context intact.

Source links and collection timestamps are retained alongside the indexed records.