Consultation on Proposed Changes to Stamp Duty Land Tax and Multiple Dwellings Relief

On 30 November 2021 HMRC published a consultation on reforms to the rules for calculating Stamp Duty Land Tax (SDLT) on acquisitions of mixed-use property and multiple dwellings relief (MDR).

HMRC has proposed amending the way in which SDLT is calculated on mixed-use property so that an apportionment method applies with the residential SDLT rates applying to the residential portion and the non-residential SDLT rates applying to the non-residential portion of the acquired property. Alternatively, it has proposed that the non-residential SDLT rates apply only if the non-residential portion of the acquired property exceeds a certain threshold.

HMRC has also proposed several options regarding the application of MDR. These include allowing MDR only if all the dwellings are purchased with the intention of using them for a qualifying business use, ignoring subsidiary dwellings and only allowing MDR for purchases of three or more dwellings.

HMRC has invited views on the advantages and disadvantages of each of these proposals. The closing date for comments is 11:45 pm on 22 February 2022.

More information available here