In Ladson Preston Limited, AKA Developments Greenview Limited v HMRC [2021] TC08197, the First Tier Tribunal (FTT) held that planning permission was not capable of satisfying the requirement of being "in the process of construction" in order for Multiple Dwellings Relief (MDR) to apply.

Neither appellant offered any evidence as to why planning permission should be construed as "in the process of being constructed".

The FTT held:

Both appeals were dismissed.

Useful guides on this topic

SDLT: At a glance, Stamp Duty Land Tax, rates & allowances
What is Stamp Duty Land Tax (SDLT)? What are the rates of Stamp Duty Land Tax (SDLT)? Stamp Duty Land Tax (SDLT) is paid on the purchase of an interest in land as a percentage of the purchase consideration. Different rates apply according to the type of property and the type of purchaser.

SDLT: Multiple Dwellings Relief
What is Multiple Dwellings Relief (MDR) for Stamp Duty Land Tax purposes? When does it apply and how is it claimed?

SDLT: Amending returns
How do I amend an SDLT return?  When can I amend an SDLT return?

External link

Ladson Preston Limited, AKA Developments Greenview Limited v HMRC [2021] TC08197


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