HMRC consultation document on SDLT

Cliff edge tax thresholds are not great for anyone’s relationship with HMRC. A case in point is that parts of the stamp duty land tax rules can produce enormous swings in outcomes which turn on a small ambiguity and interpretation regardless of a taxpayer’s intent to cause malice or not.

HMRC is doing a good thing about this and in November 2021 released its consultation document (condoc) (tinyurl.com/2p9esr44) on potential fixes for two such key areas in property tax. The condoc is unambiguously called Stamp Duty Land Tax: Mixed-property purchases and multiple dwellings relief.

The condoc

Action on mixed-use transactions is much needed though multiple dwellings relief (MDR) is the lesser of the two issues. The condoc covers:

• the taxation of ‘mixed-use’ transactions – purchases which consist of both residential and non-residential property and
• relief for purchases of two or more...