Grazing and rewilding land was not residential for SDLT purposes
In Withers v HMRC [2022] UKFTT 433 (TC) (25 November 2022) the FTT allowed the taxpayer’s appeal against a closure notice that increased the SDLT liability in respect of a land transaction which was subject to a grazing agreement with a local farmer and a rewilding agreement with the Woodland Trust concluding that the grazing and rewilding land was each used for a separate purpose and each had a self-standing function and accordingly was not residential land for SDLT purposes.
The land in question included a dwelling independent annexe with garden and grounds of circa 10 acres with a further circa 20 acres of land which was used for grazing and land which was subject to a rewilding scheme.
The grazing land had been used for such purpose continuously for 20 years albeit a formal...
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Grazing and rewilding land was not residential for SDLT purposes
In Withers v HMRC [2022] UKFTT 433 (TC) (25 November 2022) the FTT allowed the taxpayer’s appeal against a closure notice that increased the SDLT liability in respect of a land transaction which was subject to a grazing agreement with a local farmer and a rewilding agreement with the Woodland Trust concluding that the grazing and rewilding land was each used for a separate purpose and each had a self-standing function and accordingly was not residential land for SDLT purposes.
The land in question included a dwelling independent annexe with garden and grounds of circa 10 acres with a further circa 20 acres of land which was used for grazing and land which was subject to a rewilding scheme.
The grazing land had been used for such purpose continuously for 20 years albeit a formal...
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.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")