Kitchen facilities in annexe were inadequate

In 2020 the taxpayer bought a property. He filed a stamp duty land tax return in which he claimed multiple dwellings relief (MDR). After an enquiry HMRC concluded the relief was not due. The taxpayer appealed.

The property was large and included a detached annexe which comprised a three-bay garage and rooms on the first floor. These included a large main room a bathroom and an entrance lobby. It had central heating broadband mains electricity and gas water and a separate zone on the house alarm system. There was a microwave and fridge but no high-voltage electricity supply necessary for an oven or hob. The previous owner’s son used to live there.

The main issue for the First-tier Tribunal was whether the annexe was suitable for used as a dwelling. In this case the answer hinged on the cooking facilities in the kitchen area.

The...