Claim for multiple dwellings relief

The taxpayer bought a residential barn in December 2021. He claimed multiple dwellings relief on the basis that the property consisted of two dwellings.

The previous owner had at various times rented out one of the dwellings and lived in the other rented out both dwellings separately and rented out the entire property.

Dwelling 2 was the larger property and where the taxpayer’s family currently lived. It was a four-bedroom house with separate outside doors for access. Dwelling 1 which has been unoccupied since completion of the transaction comprised one large bedroom a landing a snug/office a bathroom a large living/dining area kitchen/utility room downstairs toilet office/storage room. It also has separate outside entrances.

Both dwellings were supplied by a single source of electricity and shared a boiler. Each had a separate water supply.

HMRC refused the claim. It accepted that...