TC09626 - [2025] UKFTT 01067 (TC)

HMRC argued that if the hallway was occupied as part of the Annexe then the occupants of the Main House would lack the necessary privacy because occupants of the Annexe could look through the semi-transparent glass panels in the top of the kitchen door, which had only partially been obscured by the film. HMRC also argued that as the kitchen door could be opened from both sides there was a lack of security. Accordingly, the Annexe was only suitable for occupation by family members.

The Appellants argued that the film on the glass sufficiently obscured the view.

The Appellants pointed out that the occupants of the Annexe need not be provided with a key to the kitchen door.