SDLT MDR claim denied:Shine Business Ltd v HMRC [2024] UKFTT 894 (TC) (7 October) is another in the long line of cases on the now-abolished SDLT multiple dwelling relief. Like all such appeals the decision is highly fact dependent. The FTT using the criteria set out in Fiander and Brower v HMRC [2021] UKUT 156 particularly on the meaning of the word ‘suitable’ held that the relief did not apply. A flavour of its approach to the facts can be found in this concluding paragraph: ‘The Annex does not have sufficient facilities to meet an occupier’s basic living needs. In particular we consider that neither the connecting glazed double doors (with the clear views into the Main Property and vice versa) which can be locked and therefore unlocked from both sides nor the fact that the sole external entrance to the Annex is...
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SDLT MDR claim denied:Shine Business Ltd v HMRC [2024] UKFTT 894 (TC) (7 October) is another in the long line of cases on the now-abolished SDLT multiple dwelling relief. Like all such appeals the decision is highly fact dependent. The FTT using the criteria set out in Fiander and Brower v HMRC [2021] UKUT 156 particularly on the meaning of the word ‘suitable’ held that the relief did not apply. A flavour of its approach to the facts can be found in this concluding paragraph: ‘The Annex does not have sufficient facilities to meet an occupier’s basic living needs. In particular we consider that neither the connecting glazed double doors (with the clear views into the Main Property and vice versa) which can be locked and therefore unlocked from both sides nor the fact that the sole external entrance to the Annex is...
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