SDLT linked transactions after multiple dwellings relief ended
Linked purchases across 1 June 2024
HMRC says that a linked set of property purchases can split into an earlier group that may still qualify for multiple dwellings relief and a later group that cannot.
- Check exchange, completion and substantial-performance dates.
- Only the earlier group can receive the relief.
- A claim can reset the SDLT position for the later group.
Scroll down for the full analysis.
Read the original guidance here:
SDLT linked transactions after multiple dwellings relief ended
SDLT linked transactions after multiple dwellings relief ended
If you bought several homes as part of one arrangement, the end of multiple dwellings relief may not affect every purchase in the same way. HMRC says some earlier purchases can still qualify, even where later linked purchases cannot. That split can change your stamp duty bill.
What this rule is about
Multiple dwellings relief applied when more than one home was bought at once, until it ended for SDLT purposes from 1 June 2024, subject to transition rules. Those rules matter.
Linked transactions are purchases that form one scheme, arrangement or series between the same buyer and seller, or people connected with them. SDLT normally looks across linked purchases together. That can mean one purchase affects the tax on another.
Here, HMRC explains that, where linked purchases straddle the change, a special result applies when one falls before it and another falls after it. The timing matters.
What the official source says
HMRC’s manual divides the purchases into two groups. It calls them pre-abolition and post-abolition transactions. The labels matter because the relief can only apply to the first group.
- A pre-abolition purchase completed before 1 June 2024.
- It can also be pre-abolition if substantial performance happened before that date.
- A purchase can fall within the transition where contracts were exchanged on or before 6 March 2024.
- That contract route does not work for an excluded transaction.
- A post-abolition purchase is one that completed or was substantially performed on or after 1 June 2024.
- All purchases in the group must otherwise have fallen within the former relief rules.
Where those conditions hold, HMRC says you can claim the relief only for the earlier purchases. The later purchases do not gain the relief.
After you make that claim, HMRC says the later purchases remain linked to each other. However, they stop linking to the earlier purchases. That is the key part of this guidance.
What this means in practice
For the first later purchase, HMRC says that, instead of adding its price to the earlier purchases, the SDLT calculation starts again and uses the full tax-free starting band under the relevant SDLT rates. Any extra rates that apply still matter.
Do not assume every purchase in one deal gets the same answer. The date of each purchase can split a single arrangement into two SDLT groups.
- Check each purchase date, not just the date the overall deal finished.
- Check whether substantial performance happened before completion.
- Keep the earlier and later purchases separate in your records.
- Calculate the later linked purchases without adding the earlier group.
- Consider any SDLT surcharge separately when working out the later tax.
Where a contract was exchanged by 6 March 2024, it can preserve the earlier treatment despite a later completion, provided that the transaction is not excluded. Exclusions matter.
How to analyse it
Start with the whole arrangement. Then place each purchase on the timeline. When completion occurs later, it does not always determine the outcome, since substantial performance may instead establish the effective date on which the purchase is treated. Dates can differ.
- List every property purchase that may form part of the arrangement.
- Ask whether they are linked under the SDLT test.
- Record the contract exchange date for each purchase.
- Record completion and any substantial performance date.
- Sort the purchases into pre-abolition and post-abolition groups.
- Check whether every purchase would otherwise have met the former relief rules.
- Check whether any contract-route purchase is excluded.
- Claim the relief only for the qualifying earlier group.
- Rework the later linked group from the first later purchase.
What actually decides the answer? Usually, it is not the number of homes. It is the dates, the links between the purchases and whether the old relief rules would have applied.
Example
Asha agrees to buy two homes from the same seller as one arrangement. The first purchase completes on 31 May 2024. The second completes on 10 June 2024. Assume both would otherwise have met the former relief conditions, and neither falls within an exclusion.
HMRC’s manual treats the first as pre-abolition and the second as post-abolition. Asha can claim the relief for the first purchase only. Once she does, HMRC says the second purchase stops linking back to the first. The second purchase instead starts the later group for SDLT rate purposes.
Why this can be difficult in practice
Substantial performance is often the hard part. It can happen before legal completion, so checking the completion statement alone may give the wrong date.
Rather than turning simply on timing or proximity, the legal test considers whether the purchases form one scheme, arrangement or series, and whether the required party connection exists. Both questions matter.
- People often use the completion date and miss earlier substantial performance.
- A contract signed before the change does not automatically preserve the relief.
- The 6 March 2024 transition has an exclusion that this source does not explain.
- A claim for the earlier group changes how HMRC treats the later group.
- HMRC’s manual describes its view; legislation remains the legal authority.
Key takeaways
- The relief ended for purchases with an effective date on or after 1 June 2024.
- One linked arrangement can contain an earlier group and a later group.
- HMRC says a valid earlier claim breaks the link to the later group for SDLT calculations.
Technical analysis
For advisers, and for anyone who wants to check the law behind this page. You do not need this section to understand the guidance above.
Legislation
- FA 2003 section 55 — calculating tax for single and linked property purchases
- FA 2003 section 108 — when property purchases count as linked transactions
- FA 2003 section 119 — working out a property transaction’s effective date
- FA 2003 Schedule 6B para 2 — which purchases previously fell within multiple dwellings relief
- FA 2003 Schedule 6B para 3 — meaning of relevant transaction for the former relief
Official guidance
The pages below are HMRC’s guidance. Guidance is not law. It sets out how HMRC reads the legislation, and it is not binding on you, on a tribunal or on a court. Where guidance and the legislation differ, the legislation wins. HMRC can also change or withdraw guidance, and it may not cover your facts.
Where this is not settled
- This source does not explain what makes a transaction excluded under the contract transition.
- Whether purchases are linked depends on the facts, including the parties and the overall arrangement.
- The statutory transitional provisions should be checked before relying on this guidance for a live return or claim.
Evidence you would need
This kind of case is decided on the facts of the individual property. These are the records that usually settle it, and the ones an adviser would ask you for.
- signed contracts and the date of exchange
- completion statements and completion dates
- evidence of any earlier substantial performance
- details of every related property purchase
- documents showing who bought and sold each property
- evidence of the overall arrangement between the parties
Explore this with an AI
Readers often want to test their own situation. Copy the prompt below into ChatGPT, Claude or Gemini. It hands the model the actual legislation for this page rather than letting it answer from memory, and tells it to be explicit about what is uncertain. What comes back is information, not advice – check it against the links above.
I am researching UK Stamp Duty Land Tax (SDLT), which applies in England and Northern Ireland. MY QUESTION SDLT linked transactions after multiple dwellings relief ended [Replace this with your own situation: what you are buying, the price, the dates, who the buyer is, and what you plan to do with the property.] THE LAW THIS TURNS ON - FA 2003 section 55 - calculating tax for single and linked property purchases https://www.legislation.gov.uk/ukpga/2003/14/section/55/2025-11-17 - FA 2003 section 108 - when property purchases count as linked transactions https://www.legislation.gov.uk/ukpga/2003/14/section/108/2025-11-17 - FA 2003 section 119 - working out a property transaction's effective date https://www.legislation.gov.uk/ukpga/2003/14/section/119/2025-11-17 - FA 2003 Schedule 6B para 2 - which purchases previously fell within multiple dwellings relief https://www.legislation.gov.uk/ukpga/2003/14/schedule/6B/paragraph/2/2025-11-17 - FA 2003 Schedule 6B para 3 - meaning of relevant transaction for the former relief https://www.legislation.gov.uk/ukpga/2003/14/schedule/6B/paragraph/3/2025-11-17 HMRC's guidance page on this topic (guidance, not law): https://www.gov.uk/hmrc-internal-manuals/stamp-duty-land-tax-manual/sdltm29903 HOW I WANT YOU TO ANSWER 1. Work from the legislation above. Read it before answering. HMRC guidance is HMRC's view of the law, not the law, and does not bind a tribunal or a court. 2. Tell me what the rule actually requires, in plain English. 3. Tell me which facts decide the answer, and which facts would change it. 4. Tell me what evidence I would need to support the position. 5. Be explicit about anything unsettled or fact-sensitive. Do not guess. 6. Your training data has a cutoff and SDLT rates and reliefs change at fiscal events. Say so if you are not sure the law is current. POINTS ALREADY KNOWN TO BE UNCERTAIN ON THIS TOPIC - This source does not explain what makes a transaction excluded under the contract transition. - Whether purchases are linked depends on the facts, including the parties and the overall arrangement. - The statutory transitional provisions should be checked before relying on this guidance for a live return or claim. Do not give me a conclusion you cannot support from the provisions above.
Legislation links show Finance Act 2003 as it stood on 2025-11-17. The law may have changed since, and the rules that apply are those in force on the date of your transaction. The official guidance this page is based on is here.
This page was last updated on 1 September 2026
Useful article? You may find it helpful to read the original guidance here: SDLT linked transactions after multiple dwellings relief ended
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