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Multiple Dwellings Relief v Commercial Rates

Tom, a property developer, is planning to purchase a block of 15 flats for the total consideration of £1.7m. He used the HMRC SDLT calculator which gave a result of £168,750 and he has asked for confirmation of this figure and if any reliefs would be available to reduce the SDLT payable on the proposed transaction.


  • As Tom is purchasing from the same vendor as part of one deal, the transaction will be considered to be a ‘linked transaction’ and therefore the total consideration is aggregated.
  • The 3% surcharge will be applied as it is a multiple dwelling transaction and none of the flats fall within the definition of a subsidiary dwelling.
  • On first principles, if the Table A rates (residential) are applied along with the 3% surcharge, the SDLT payable would be £168,750;
  • However, the legislation specifically provides that where 6 or more dwellings are purchased, they will not be treated as residential property. Accordingly, the rates at Table B (non-residential) should be applied, resulting in the total tax payable of £74,500.
  • Moreover, a claim for Multiple Dwellings Relief (MDR) could be claimed as more than 2 properties are being purchased. If MDR is claimed, the above rule of using Table B is disapplied, so that Table A (using the 3% surcharge) is applied to the average price of each flat and this figure is then multiplied by the number of flats. A claim for MDR would result in SDLT payable of £51,000.
  • MDR is not automatic and must be claimed in the SDLT return. Amendments to the SDLT return can be made within 12 months of the filing date of the original return.
SDLT is becoming increasingly complex. If in doubt, seek professional advice.

If you have any queries around SDLT please do not hesitate to get in contact via our SDLT Advisory Service.

Although we have taken every step to ensure that the information in this presentation is correct at the time of writing, we cannot accept responsibility for any loss occasional to any person as a result of action or refraining from action in consequence of any item herein. This document is not a substitute for professional advice.

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