British Virgin Islands registered Chifley Holdings Limited (BVI) took HMRC to the Upper Tribunal Lands Chamber to defend its calculation of ATED for a property it owned in Belgravia in London through an offshore company.

The property at the centre of this appeal was a five-bedroom, four-storey Grade II listed house with an integrated mews building and garage in Chester Square in Belgravia in London, situated within a prime residential neighbourhood and its value on 1 April 2017.

HMRC determined the value as £11,750,000, which meant the property fell into the £10-£20m bracket for the purposes of ATED.

However, the appellant, Chifley Holdings disputed HMRC’s valuation, arguing that the value of the appeal property was £9,325,000, thus falling within the sub-£10m bracket.

A