This was an appeal by the Appellant against the decision of HMRC that their claim under the DIY Housebuilders scheme was outside of the three month time limit for submitting claims.
Two brothers inherited land on which the built two houses, one was first occupied on 20 December 2012 and the second in March 2013. Neither house was complete and only just habitable. The Local Authority carried out a completion inspection on 9 May 2016 which identified a number of items that needed to be addressed before a completion certificate could be issued.
Following the completion of the outstanding works a Completion Certificate was issued by the Local Authority on 15 January 2018.
The Regulations state that one of the documents required by HMRC to be submitted with the claim was the Certificate of Completion.
â¯The Appellants submitted that it was unreasonable for HMRC to refuse to treat the date of
