In two separate cases – 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 decided inter alia that the main house and annex were not each suitable for use as a single dwelling for the purposes of multiple dwellings relief (MDR). Under FA 2003 Sch 6B para 7 a building (or part of a building) counts as a dwelling if it is used or suitable for use as a single dwelling or it is in the process of being constructed or adapted for such use. In both cases FTT in both cases followed the reasoning set out in Fiander and Brower [2020] UKFTT 190 (TC) to establish whether the appellants acquired two single dwellings or one and found that the annex did not have...
