Decision Number: | TC 08247 |
Appellant: | Robert David George & Rachel Claire George |
Respondent: | The Commissioners for Her Majesty's Revenue & Customs |
Chairmen / Special Commissioners: |
Dr Heidi POON |
Date Of Decision: | 26/08/2021 |
Main Category: | PROCEDURE |
Main Subcategory: | Other |
Notes: | STAMP DUTY LAND TAX - Multiple Dwellings Relief - para 7(2)(b) Schedule 6B Finance Act 2003 - whether annex of property -˜suitable for use as a single dwelling-™ - case law meaning of -˜dwelling-™ in other legal contexts and extrinsic aid to statutory construction set aside - guidance from Fiander UT followed - objective assessment of physical attributes of property at effective date - integral character in design layout and access - whether privacy and security critically compromised - whether separate, self-contained living unit - absence of kitchen facilities considered - suitability for use limited to a particular type of occupant - appeal dismissed |