The Upper Tribunal was satisfied that the First-tier Tribunal was entitled to find that the property was not configured in such a way that it comprised two self-contained living units generally suitable for separate occupation, but was suitable for use as a single dwelling.

The appellants acquired a property in London for £2,700,000 in August 2017. The appellants initially declared and paid stamp duty land tax (SDLT) of £237,750 but subsequently requested a refund of £80,250 on the basis that the property qualified for multiple dwellings relief (MDR). Following an enquiry, HM Revenue and Customs issued a closure notice disallowing