Appellant Daniel Ridgway initially won his stamp duty land tax (SDLT) appeal at the First Tier Tribunal (FTT) but after HMRC disputed this the Upper Tribunal reversed the decision.

The £6.5m property in Oxford consisted of land and buildings and was bought on 23 August 2017 by multiple owners as it consisted of two separate titles.

Ridgway was advised that, because at the time of purchase the building known as the Old Summer House was being used as a garage and an artist’s studio, he would be able to claim multiple dwellings relief.

He submitted an SDLT return on 1 September 2017 stating it was mixed use, paying £314,500 in tax. The full SDLT charge would have come to £888,750 but with multiple dwellings relief was reduced to £577,500.