is this residence too sub-divided for rent-a-room relief?

is this residence too sub-divided for rent-a...

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Hello, I would appreciate some help with this. I am unsure whether this rental situation is eligible for rent-a-room relief -

My client has created a basement flat in the main residence and rented it to a lodger/tenant.

The internal stairway has been properly blocked off from the upstairs but not with brick. There is sound-proof partitioning and cupboards. The stairs remain, presumably. The flat has its own entrance, the main point which makes me query whether it is allowable for R-a-R. The flat is, however, dependent on upstairs for water, heating and electricity i.e. the meters and boiler are upstairs, there has been no separation of utilities. Rent is charged inclusive of heat, power and water.

My client has not contacted the council tax office for their view but this is not so much because there may be extra tax to pay (as the tenant would bear this) but because he is intending long-term to reintegrate the house and does not want any planning issues in going back to that situation. 

Looking at PIM4004, it asks that I consider how temporary the division is based on various factors. Can anyone guide me in weighing up the situation here?

Thanks for any help.

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