The Upper Tribunal (UT) has rejected the company’s appeal from the First-tier Tribunal (FTT) in Ladson Preston Ltd v HMRC  UKUT 301 (TCC). The case considered whether buildings were in the process of being constructed for use as dwellings, the effective date of transaction, and whether activities undertaken after the time of completion of the transaction were relevant to determining the chargeable interest acquired.
The rules relating to multiple dwellings relief are given at FA 2003, Sch. 6B.
The concept of the “effective date” is found at FA 2003, s. 119.
The UT found that the FTT had erred on one part of the law, but remade that part of the FTT decision, leaving the result unchanged.
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