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UK Tax Podcast · May 7, 2025 · 5 min

SDLT Mixed Use and recent cases

Send us Fan Mail In this episode of The UK Tax Podcast, John Kavanagh explores the rules for claiming mixed-use treatment on property purchases for SDLT purposes. He examines recent tribunal decisions, including Ridgway, Tretyakov, and Suterwalla, and considers how the courts have interpreted residential versus non-residential use at the time of completion. The episode highlights HMRC’s increasingly aggressive stance on such claims, the importance of timing and supporting evidence, and how minor differences in fact patterns can affect the outcome. John also discusses how advisers should assess the risk of enquiry before submitting a reclaim or advising on mixed-use eligibility. Tune in for practical commentary on one of the more contentious areas of SDLT and what recent cases mean for taxpayers and advisers alike.

0:00-5:01

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Send us Fan Mail

In this episode of The UK Tax Podcast, John Kavanagh explores the rules for claiming mixed-use treatment on property purchases for SDLT purposes. He examines recent tribunal decisions, including Ridgway, Tretyakov, and Suterwalla, and considers how the courts have interpreted residential versus non-residential use at the time of completion. The episode highlights HMRC’s increasingly aggressive stance on such claims, the importance of timing and supporting evidence, and how minor differences in fact patterns can affect the outcome. John also discusses how advisers should assess the risk of enquiry before submitting a reclaim or advising on mixed-use eligibility.

Tune in for practical commentary on one of the more contentious areas of SDLT and what recent cases mean for taxpayers and advisers alike.

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