MR AND MRS MULLANE V HMRC [2021]

This case was about multiple-dwellings relief and it contains a number of judicial comments favourable to taxpayers claiming MDR in the context of an annexe that is joined to the main dwelling. However, the suggestion that an intention to let the annexe out is necessary to claim MDR is quite a novel suggestion and could lead to problems for both taxpayers and HMRC.

Read the full decision here.

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L-L-O CONTRACTING LIMITED AND OTHERS V HMRC [2025] UKUT 00127 (TCC)

This was the hearing before the Upper Tribunal of the appellants' claims for overpayment relief from SDLT under paragraph 34 Schedule 10 FA 2003 in circumstances where the appellants had failed to claim Multiple Dwellings Relief ("MDR") in their return or in an amendment to their return, within 12 months...

CHARLIE JOHNSON V HMRC TC/2024/00254

This was a successful appeal by the taxpayer about whether multiple dwellings relief ("MDR") from SDLT applied to his purchase of a residential property with a self-contained annex. In a carefully structured and considered decision the FTT reviewed the evidence thoroughly and held that HMRC's objections concerning the interconnecting doors and shared...

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