Abolition of Multiple Dwellings Relief for SDLT: Linked Transactions Guidance

Linked transactions after the end of Multiple Dwellings Relief from 1 June 2024

When linked property transactions fall partly before and partly after 1 June 2024, Multiple Dwellings Relief (MDR) can only still apply to qualifying pre-abolition transactions. If MDR is actually claimed for those earlier transactions, the later post-abolition transactions are treated as no longer linked to the earlier group for SDLT rate-setting, although later post-abolition transactions may still remain linked to each other.

• Pre-abolition transactions are those completed or substantially performed before 1 June 2024, or those under contracts exchanged on or before 6 March 2024 if they are not excluded transactions.
• Post-abolition transactions are those with an effective date on or after 1 June 2024 that would previously have fallen within the MDR rules.
• Where linked transactions straddle the change, MDR is not available for the post-abolition transactions.
• If MDR is claimed for any qualifying pre-abolition transaction, the later post-abolition transactions are treated as starting a new linked group for SDLT purposes.
• This can give the first post-abolition transaction a fresh SDLT calculation, including access to the normal nil-rate band, subject to any surcharge.
• Care is needed because the outcome depends on the effective date, whether the transactions would otherwise have qualified for MDR, whether any exclusion applies, and whether an MDR claim has actually been made.

Scroll down for the full analysis.

How linked transactions are treated after the abolition of Multiple Dwellings Relief from 1 June 2024

This page explains what happens where a buyer has a series of linked land transactions and some fall before the abolition of Multiple Dwellings Relief (MDR) on 1 June 2024 while others fall after it. The point matters because linked transactions are normally considered together for SDLT, but the transitional rules change that position in a specific way where MDR is partly preserved for earlier transactions only.

What this rule is about

MDR was abolished for SDLT for transactions with an effective date on or after 1 June 2024, subject to transitional rules. The issue covered here is not the general abolition itself, but a narrower problem: what to do when a set of linked transactions straddles the change in law.

That can happen, for example, where a buyer acquires more than one dwelling from the same seller, or as part of a single scheme or arrangement, but completion dates fall on different sides of 1 June 2024. Some transactions may still qualify as “pre-abolition” transactions under the transitional rules. Others may be “post-abolition” transactions and no longer qualify for MDR.

The rule is designed to separate those two groups in a controlled way.

What the official source says

HMRC’s manual says the abolition of MDR applies to land transactions with an effective date on or after 1 June 2024. It then distinguishes between:

• pre-abolition land transactions, and
• post-abolition land transactions.

According to the manual, pre-abolition transactions are those that either:

• complete, or are substantially performed, before 1 June 2024, or
• arise under contracts exchanged on or before 6 March 2024, provided the transaction is not an excluded transaction.

Post-abolition transactions are those which would previously have been relevant transactions for MDR, but are no longer so because they complete or are substantially performed on or after 1 June 2024.

Where:

• there are pre-abolition transactions linked with post-abolition transactions, and
• all of those transactions would, apart from the abolition, have been relevant transactions for MDR under Schedule 6B Finance Act 2003,

the manual says that:

• MDR can be claimed only for the pre-abolition transactions, and
• if a claim is made for any of those pre-abolition transactions, the post-abolition transactions are then treated as no longer linked to the pre-abolition transactions, although they remain linked to each other.

HMRC explains that this effectively resets the SDLT position at the point of the first post-abolition transaction. In practical terms, that means the first post-abolition transaction is not dragged into the earlier linked group for rate-setting purposes. Instead, it starts a new linked group with any later post-abolition transactions.

What this means in practice

The key practical point is that a buyer cannot use MDR for the post-abolition part of a linked series. MDR, if available at all, survives only for the pre-abolition transactions.

But the transitional rules do something important in return. If MDR is claimed for the pre-abolition transactions, the later post-abolition transactions are treated as detached from that earlier group. That matters because linked transaction rules can increase SDLT by requiring the tax to be calculated by reference to the total consideration across the linked purchases.

Without this reset, a later post-abolition purchase might have been taxed by reference to the cumulative value of both the earlier and later transactions. The transitional rule prevents that where the conditions are met and an MDR claim is made for the pre-abolition transactions.

HMRC says this allows the buyer to benefit from a full nil-rate band on the first post-abolition transaction, using the usual SDLT rates under section 55 Finance Act 2003 and taking account of any surcharge that may apply. In other words, the first post-abolition transaction is tested afresh rather than being stacked on top of the earlier pre-abolition acquisitions.

How to analyse it

A sensible way to analyse a case is to ask these questions in order:

• Are the transactions linked under the ordinary SDLT linked transaction rules?
• Would all of them, ignoring the abolition, have been relevant transactions for MDR under Schedule 6B Finance Act 2003?
• For each transaction, what is its effective date?
• Is each transaction a pre-abolition transaction or a post-abolition transaction under the transitional rules?
• If a transaction is being treated as pre-abolition because contracts were exchanged on or before 6 March 2024, is it an excluded transaction? If it is excluded, that route into transitional protection is not available.
• Has an MDR claim actually been made for one or more of the pre-abolition transactions?

That last question is important. The manual says the de-linking effect applies if such a claim is made in relation to any of the pre-abolition transactions. On the wording provided, the reset is tied to an actual MDR claim for the earlier transactions, not simply to the fact that those transactions could in principle have qualified.

You should therefore distinguish carefully between:

• whether the earlier transactions remain eligible for MDR, and
• whether the later transactions are treated as no longer linked to them.

On HMRC’s explanation, those later transactions are treated as no longer linked to the earlier ones when an MDR claim is made for the pre-abolition group.

Example

Illustration only.

A buyer enters into a series of linked purchases of dwellings that would all have fallen within the MDR rules before abolition. The first purchase completes before 1 June 2024, so it is a pre-abolition transaction. A second purchase completes on or after 1 June 2024, so it is a post-abolition transaction.

If the buyer claims MDR for the earlier pre-abolition transaction, MDR is not available for the later post-abolition transaction. However, the later transaction is treated as no longer linked to the earlier one. The SDLT calculation for that later transaction therefore starts again from that point, subject to the normal rate rules and any surcharge that applies.

If there are further post-abolition transactions, they may still remain linked with each other.

Why this can be difficult in practice

The main difficulties are classification and timing.

First, everything turns on the effective date, not just the contract date. A transaction completing on or after 1 June 2024 will usually be post-abolition unless it falls within the transitional protection for contracts exchanged on or before 6 March 2024 and is not excluded.

Second, the rule only applies in the way described where the transactions would otherwise have been relevant MDR transactions. If one of the linked transactions falls outside Schedule 6B Finance Act 2003, the analysis may be more complicated.

Third, the manual wording links the de-linking effect to an MDR claim being made for the pre-abolition transactions. That means the filing position may affect the rate treatment of the later transactions. Readers should not assume that the reset happens automatically in every mixed pre- and post-abolition case without checking whether the statutory conditions and claim requirements are satisfied.

Finally, the manual refers to “excluded transactions” but does not set out their meaning on this page. That issue must be checked separately when a taxpayer is relying on the exchange-before-6-March-2024 transitional route.

Key takeaways

• MDR is preserved only for qualifying pre-abolition transactions, not for post-abolition ones.
• If an MDR claim is made for the pre-abolition transactions, later post-abolition transactions are treated as no longer linked to the earlier group, though they may still be linked to each other.
• This reset can materially affect SDLT on the first post-abolition transaction because it starts a new linked group for rate-setting purposes.

This page was last updated on 24 March 2026

Useful article? You may find it helpful to read the original guidance here: Abolition of Multiple Dwellings Relief for SDLT: Linked Transactions Guidance

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