Conditions for additional dwelling supplement repayment not satisfied

Before he was deployed to Brazil by his employer the taxpayer had owned a property in England where he lived with his family. On his return to the UK he was deployed in Scotland where he and his family initially lived in rented accommodation. On 29 March 2019 he bought a house in Scotland. He submitted a land and buildings transaction tax return and because he owned two properties had to pay additional dwelling supplement on the Scottish house.

Having settled in Scotland he decided to sell the property in England. It had been his main residence at one time and he believed that if he sold it within 18 months he could reclaim the additional dwelling supplement. He completed on the sale on 13 November 2020 and claimed a repayment of the additional dwelling supplement on 3 March 2021 on the basis that he had sold...