TC09626 - [2025] UKFTT 01067 (TC)

HMRC argued that if the hallway was occupied as part of the Main House then the occupants of the Annexe could gain access to the hallway and the rest of the Main House because the door to the Utility is only lockable from inside the Annexe. This did not exclude the occupiers of the Annexe and so did not provide the occupiers to the Main House with sufficient privacy and security.

The Appellant’s main case was that the occupier of the Annexe would not have access to the hallway due to the Utility door and, in any event, the kitchen door giving access to the Main House was lockable from the inside and so ensuring security.