A property was not acquired ‘exclusively’ by the appellant company for the purpose of a qualifying property rental business, and accordingly relief from the higher rate of stamp duty land tax was not due.
The appellant’s business was primarily to arrange the provision of self-employed carers to persons needing their services and to receive fees.â¯On 15 December 2015, the appellant exchanged contracts with the seller to purchase a property for £930,000. The property had been advertised for sale as a family home. Completion occurred on 21 December 2015, which was the effective date of the purchase.
The appellant received permission from Tonbridge & Malling Borough Council on 15 December 2015 to change the use of the property from a dwelling to a temporary residence for residential carers. The appellant refurbished and updated the property. Since that work was
