Property tax

SDLT appeal on annexe allowed

The taxpayer bought a house and initially paid stamp duty land tax (SDLT) as normal, then submitted a reclaim on the basis that multiple dwelling relief was available. HMRC disputed that the annexe was a valid separate dwelling, as there was a shared garden and a door that connected the house and annexe, reducing privacy and security.

The First-tier Tribunal (FTT) found for the taxpayer that the annexe was a separate dwelling. It had its own front door and was separately registered for council tax. It had cooking and washing facilities. The connecting door had been blocked with a door brace, and use of the garden could be addressed in a tenancy agreement.

Johnson v HMRC [2025] UKFTT 50 (TC)

From Tax Update January 2025, published by Evelyn Partners LLP