This site uses cookies. By continuing to browse the site you are agreeing to our use of cookies. To find out more about cookies on this website and how to delete cookies, see our privacy notice.

Property and annexe comprised two dwellings for multiple dwellings relief purposes

By Mark McLaughlin, May 2026

At the time of completion of its acquisition, a property and an annexe comprised two dwellings for SDLT multiple dwellings relief purposes, and not a single dwelling as HMRC had argued.
 
The appellants purchased a property for £797,000 on 23 August 2021. The property comprised the main property and an annexe. The annexe consisted of: (a) a kitchen comprising a sink, food preparation surfaces, cupboards and an electrical socket for white goods and associated plumbing. It did not contain an oven or hob; (b) a ground floor shower room with a toilet, sink and shower; and (c) a studio room or office or sitting room which could be used as a living space or bedroom. 

The annexe could be accessed in three ways: (a) from the driveway of the property, through an external door into the garage and a further lockable door leading to the annexe. Occupiers of the main property could not access the garage internally from the main property but

Subscribe to the McLaughlin’s Tax Case Library to get instant access
to the Tax Case Library.
14 day free trial , 90 day money back guarantee
Subscribe

Related or similar articles

Acquisitions of apartment and storage unit were separate but linked transactions and non-residential SDLT rates applied
By Mark McLaughlin, February 2026
Property was wholly residential as a part used commercially was suitable for use as a dwelling
By Mark McLaughlin, March 2025
Paddock was not part of the grounds of a dwelling
By Mark McLaughlin, July 2023
Grounds of property were not mixed use by reason of a public right of way
By Mark McLaughlin, December 2022
Follower notice: Penalty for failure to take corrective action set aside
By Mark McLaughlin, April 2020