Interaction between multiple dwellings relief and other additional SDLT charges

Stamp duty land tax has gained a lot of attention of late from advisers and taxpayers alike. Its popularity is due to planning opportunities arising from a combination of the temporary holiday rates implemented between 8 July 2020 and 30 September 2021 and increased knowledge about various reliefs available.

It is one of the lesser-known taxes but it is gaining traction. In 2020 and 2021 there were an abundance of cases addressing uncertainties relating to an increasingly popular relief known as multiple dwellings relief (MDR). Historically a lack of case law and patchy guidance led to an almost wild west approach and a few pushed the boundaries within the grey areas of this relief.

This article will focus on the interaction between the 1% minimum under MDR and other additional charges that arise within stamp duty land tax.

Multiple dwellings relief

When two or more dwellings are...