HMRC v CHRISTIAN PETER CANDY [2026] UKUT 00282 (TCC)

Upper Tribunal Tax and Chancery decision of MR JUSTICE CAWSON and JUDGE ASHLEY GREENBANK on 27 July 2026

• From: HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
• Published: 28 July 2026

• Category: Tax
• Release date: 27 July 2026

Read full decision: HMRC v CHRISTIAN PETER CANDY

SDLT – overpayment relief – paragraph 34 Schedule 10 Finance Act 2003 – substantial performance of contract not carried into effect – taxpayer out of time to amend land transaction return – whether claim for overpayment relief barred by section 44(9) Finance Act 2003 – no – appeal dismissed

Published 28 July 2026