Tax analysis: In Patel v HMRC, the First-tier Tax Tribunal (FTT) dismissed the taxpayer’s appeal against an assessment for Stamp Duty Land Tax (SDLT) on the purchase of a partly completed development with planning permission to convert two properties into one house. The FTT held that the properties were in the process of being constructed or adapted for use as a dwelling so that the residential rate of SDLT applied.
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