A parent’s and daughter’s co-purchase and co-ownership of the daughter’s residence was liable to land transaction tax at the higher rates, notwithstanding that the parent’s involvement in the transaction was solely to meet mortgage affordability requirements.  

A property in Trowbridge was acquired with an effective date of 28 May 2021 for £136,000. The buyers of the property on the property transfer form (TR1) and land transaction return submitted to the Welsh Revenue Authority (WRA) were the appellant and her daughter (OH). The property was intended to be, and was always, the home of OH; the appellant did not and never intended to liveliving in the property. The appellant was a borrower under the mortgage to buy the property. She owned another property with her husband, in which she lived. 

The land transaction return in respect of the purchase of the property was submitted on 2 June 2021. The return