A basement storage unit acquired with an apartment was not ‘an interest in or right over land that subsists for the benefit’ of the apartment, such that the non-residential rates of stamp duty land tax applied to the transaction
On 14 January 2022, the appellants entered into an agreement to purchase an apartment in a building. In the same agreement, the appellants agreed to purchase a car parking space, and a storage unit. A single premium of £18,250,000 was payable in respect of the apartment, the car parking space, and the storage unit. Completion of the sale of all three elements took place on 4 March 2022. The leases of the apartment and car parking space were acquired by a single form TR1. The TR1 made no reference to the storage unit but the ‘consideration’ 
