The appellants, Afshin Sajedi, Akram Rafie, Phillip Hall and Trusha Pillay were the purchasers of two separate properties, The Manor House, and a property in Prestbury Road.

The two matters were heard in a single tribunal as they concerned the application of the same rules.

The Manor House was bought for £3.6m on 19 May 2017 by Phillip Hall and Trusha Pillay, with HMRC receiving the land transaction return on the same day for £453,750. This was later reduced through a multiple dwellings relief (MDR) claim to £367,500 in November 2017.

In May 2020 a TR1 transfer form was completed by Hall and Pillay related to a different house in New Crane Wharf in Wapping, London. As part of the transaction, £19,000 was transferred from Pillay to Hall, and Hall transferred 1% of his ownership to Pillay, leaving Hall with 49% of this property.