United Kingdom Tax Tribunal Clarifies Application of Stamp Duty Land Tax for Mixed-Use Property Transactions

The United Kingdom First-Tier Tax Tribunal Nov. 24 issued a judgment in Case No. TC09696, clarifying the application of stamp duty land tax (SDLT) rates to mixed-use property transactions. The taxpayers, a married couple, claimed an SDLT refund at non-residential rates for the purchase of an apartment, a car parking space, and a storage unit. The Tax Agency denied their claim for a refund of SDLT at non-residential rates, contending that the entire transaction was residential. On appeal, the Tax Tribunal found that: 1) the apartment and storage unit were separate legal interests and weren’t appurtenant or pertaining to each ...