ANDREW AND TIFFANY DOE V HMRC [2022] UKUT 00002 (TCC)

This was the appeal to the Upper Tribunal in a case involving a claim for multiple dwellings relief in respect of a main house and annexe. The decision deals with the test for a single dwelling in paragraph 7(2) Schedule 6B to the Finance Act 2003 and the application of principles in Fiander and Brower.

Patrick Cannon represented the appellants (as he had done before the FTT). The decision contains some helpful guidance on the need to clearly identify a challenge to the FTT’s evaluative judgment as such on appeal and the high bar that exists to such challenges.

You can read the full decision here