The taxpayer won at the FTT by arguing for the use of a floor-based method as a proxy for property overheads, but this decision was overturned on appeal. The UT found that the FTT had failed to address HMRC’s core argument on dual use and agreed that the taxpayer’s method was flawed. The floor-based method does not provide a more precise determination of economic use compared to the standard method.
Source KPMG