In two decisions – A Doe and another v HMRC (TC06712) (25 January 2021) and E Partridge and another v HMRC [2021] UKFTT 6 (TC) (13 January 2021) – the FTT held that a main house and annex were not each suitable for use as a single dwelling and therefore counted as a single dwelling which meant that SDLT multiple dwellings relief (MDR) was denied.
In Doe the appellants bought a house with a separate lockable annex on the first floor. The annex contained a bedroom bathroom and kitchen. It had its own boiler electricity and doorbell. The main house consisted of rooms on the ground floor (including the bathroom) and two bedrooms upstairs (separated from the annex by six steps and lockable doors). Both the annex and the main house shared a front door a hallway and stairs. The doors leading off the communal hallway...
