In J Winfield v HMRC [2024] UKFTT 734 (TC) (7 August) the FTT allowed the taxpayer’s appeal against HMRC’s closure notice disallowing his claim for SDLT multiple dwellings relief (MDR).
The taxpayer purchased in a single transaction a property which included two distinct areas of accommodation. These were for convenience referred to as ‘dwelling 1’ and ‘dwelling 2’. Dwelling 2 where the taxpayer’s family lived comprised four bedrooms two bathrooms living areas and separate outside doors. Dwelling 1 which was unoccupied included one large bedroom a living/dining area kitchen bathroom and separate outside entrances. Sound and fireproof doors separated the two dwellings which had originally been a single dwelling. Both dwellings shared a single oil-fired boiler for hot water and central heating with separate thermostats for radiators. While there were two electricity meters ...
