INVESTMENT AND SECURITIES TRUST LIMITED v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2025] UKUT 00331 (TCC)

Upper Tribunal Tax and Chancery decision of JUDGE JONATHAN CANNAN and JUDGE ANDREW SCOTT on 06 October 2025

• From: HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
• Published: 7 October 2025

• Category: Tax
• Release date: 6 October 2025

Read full decision INVESTMENT AND SECURITIES TRUST LIMITED v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS

Stamp Duty Land Tax – high-value residential transaction – paragraph 5 Schedule 4A FA 2003 – whether chargeable interest acquired exclusively for the purpose of development or redevelopment and resale in the course of a property development trade – Annual Tax on Enveloped Dwellings – section 138 FA 2013 – whether single dwelling interest held exclusively for the purpose of developing and reselling the land in the course of a property development trade – whether FTT erred in law in identifying other purposes

Published 7 October 2025