The How Development 1 Ltd (How Development) challenged HMRC’s view that the woodland within the curtilage of a country house was residential land, and thus the whole was not a mixed use purchase for SDLT (TC08194).
How Development purchased ‘The How’ estate for £2.8m in 2018. The estate comprised of a main house, lodge house, outbuildings, areas formerly used as market gardens, orchards, gardens and large grounds set in 15.7 acres. Included within the estate was a wooded area to the south comprising of approximately two acres. The wooded area was not easily accessible by the inhabitants and runs alongside an ancient nature reserve known as The Thicket.
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