ARTICLE · 19 OCTOBER 2021

Crippin: Another Perspective On Two Dwellings

Berg Kaprow Lewis

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Relax. This is not yet another in the long line of Stamp Duty Land Tax Multiple Dwellings Relief cases which seem, like Banquo's descendants, to ‘stretch out to th' crack of doom'.

United KingdomTax

Relax. This is not yet another in the long line of Stamp Duty Land Tax Multiple Dwellings Relief cases which seem, like Banquo's descendants, to 'stretch out to th' crack of doom'. It's about the extent of a 'main residence' for the purposes of Capital Gains Tax.

The case is Crippin v HMRC [2021] UKFTT 351 (TC).

In 2006 Mr Crippin had bought a property in Scotland comprising a house ('Loaningdale') and what is described in the case as 'an adjacent annex'. He lived there with his partner Ms McKean and their children.

In 2010-11 work was done on the annex converting it to a three-bedroom flat (though one bedroom was 'due to its small size' used as a home office) with its own kitchen and bathroom facilities, and it became known as 'Benko'.

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