The taxpayer bought a property which comprised a main dwelling annex garage with studio and four outbuildings. She submitted a stamp duty land tax (SDLT) which did not include a claim for multiple dwellings relief (MDR). She later amended the return to claim MDR which HMRC refused.
The taxpayer appealed.
The First-tier Tribunal found that the annex had the ‘necessary physical configuration and facilities’ to meet a person’s basic needs namely to sleep and address personal hygiene. It was private and secure from the main dwelling in that it had its own external entrance and was separated by an internal lockable door. It had a kitchenette so the occupant could store and prepare food. Further its utilities could be controlled from within the annex. The fact that it did not have separate water or electric meters did not ‘diminish’ the annex’s level of self-sufficiency....
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