SDLT multiple dwellings relief: claims before 1 June 2024 can separate later linked purchases
Linked purchases around 1 June 2024
HMRC says an earlier multiple dwellings relief claim can affect whether a later part of the same property deal is treated separately for SDLT.
- Check completion dates and earlier SDLT returns.
- A later purchase may get its own tax-free starting band.
- Mixed property and purchases of six or more homes need separate checks.
Scroll down for the full analysis.
Read the original guidance here:
SDLT multiple dwellings relief: claims before 1 June 2024 can separate later linked purchases
SDLT multiple dwellings relief: claims before 1 June 2024 can separate later linked purchases
If you bought homes in stages around 1 June 2024, do not assume HMRC will work out stamp duty across the whole deal. HMRC says the answer can change if you claimed the relief for buying more than one home at once before that date.
What this rule is about
Multiple dwellings relief let a buyer claim relief when buying more than one home at once, and HMRC’s examples consider one deal with several completions around 1 June 2024. Some occur before that date; others occur after.
When the same buyer and seller make purchases as one deal, the law usually treats them as linked. The law calls them linked transactions. HMRC then considers their prices together when working out SDLT.
That can remove a second tax-free starting band. It can also change which rate bands apply.
But HMRC’s manual sets out a special transitional result when a buyer claimed relief on the earlier part. HMRC may instead treat the later part as separate.
What the official source says
HMRC says a buyer can still use multiple dwellings relief if the buyer completed the purchase before 1 June 2024 and met its conditions. A purchase completed on or after that date cannot make a new claim.
- If the earlier purchase covered at least two homes and used the relief, HMRC says the later purchase is not treated as linked to it.
- The later purchase is then worked out on its own under the normal SDLT rules.
- That later purchase gets its own tax-free starting band.
- Any extra stamp duty charge, such as the charge for an additional home, may still apply.
- If the earlier purchase was only one home, there was no multiple dwellings relief claim to make.
- In that case, HMRC says a later linked purchase remains linked to the earlier one.
- The combined linked-purchase calculation then applies, with one tax-free starting band across the linked purchases.
This distinction sounds small. It can change the bill by thousands of pounds.
The source also covers mixed property. That means a purchase containing homes and business space, such as a shop with flats above it. You may then need to use the non-residential table.
What this means in practice
Start with completion dates, not the date you first discussed the deal. A single commercial arrangement can have different SDLT results for different parts of it.
When a buyer claimed relief for an earlier multi-home purchase, HMRC takes the view that a post-1 June purchase stands alone, even where both acquisitions form part of the same overall deal. The shared seller does not carry the link across.
- Check every completion date.
- Check how many homes were included in each completed part.
- Find the SDLT return for the earlier purchase.
- Check whether it included a multiple dwellings relief claim.
- Identify any shop, office, yard, or other business element.
- Work out whether the later part involves six or more separate homes.
- Consider any extra stamp duty charge separately.
There is a different answer if the buyer made no earlier relief claim. HMRC’s third example makes this clear for mixed property.
Suppose the first purchase was one home. The next purchase is a shop with two flats, and the buyer makes no relief claim. HMRC says the normal linked-purchase rules continue across both purchases and any later part of the same deal.
How to analyse it
Work through the facts in order. Do not begin with the rate table.
- List every property and its completion date.
- Group purchases that may be one scheme, arrangement, or series.
- Check whether the buyer and seller are the same, or connected.
- Separate purchases completed before 1 June 2024 from those completed later.
- For each earlier multi-home purchase, check whether multiple dwellings relief was claimed.
- If it was claimed, apply HMRC’s stated transitional approach to the later purchase.
- If it was not claimed, test the whole series under the normal linked-purchase rules.
- Choose the residential or non-residential table by looking at the land bought.
- Check whether six or more homes are in one purchase.
- Recalculate earlier SDLT if a later linked purchase increases it.
What actually decides the result? In these examples, it is not simply that there are several homes. The key point is whether the buyer made an earlier qualifying claim.
Example
Amir completes on two homes from one seller on 14 March 2024. He claims multiple dwellings relief on that purchase. On 14 June 2024, under the same overall deal and with the same seller, he completes on two more homes after completing the first two in March. HMRC says Amir cannot claim the relief for the June purchase.
However, HMRC also says it does not treat the June purchase as linked to the March purchase. HMRC therefore works out the June SDLT separately and gives it its own tax-free starting band.
Change one fact. If Amir had bought only one home in March, he could not have claimed the relief then. HMRC says the June purchase remains linked and recalculates SDLT across both purchases with only one starting band.
Why this can be difficult in practice
People often focus only on the later completion. That is the expensive mistake. The earlier return, and the choice the buyer made on it, may decide whether HMRC separates the later purchase.
Mixed property adds another layer. HMRC does not deal with a shop with flats above it in the same way as an all-residential purchase.
- Calling a deal “separate” does not settle whether it is linked for SDLT.
- One home and two homes produce different transitional outcomes in HMRC’s examples.
- A claim made on the earlier return matters.
- A decision not to claim can keep later purchases linked.
- Six or more homes in one purchase have a separate statutory rule.
- If later linked purchases create extra tax on an earlier one, a further return may be needed.
Finance Act 2003 section 81A says that, where a later linked purchase creates additional tax on an earlier purchase, the buyer must send a further return within 30 days after the later purchase’s effective date. The extra tax is due by that filing date.
HMRC’s fourth example also gives a choice for a company buying 30 homes in two batches of 15. The company may use the old relief for the first batch and treat the second batch separately under HMRC’s approach. Alternatively, it may use the statutory six-or-more rule for both batches, keeping them linked.
Key takeaways
- A post-1 June 2024 purchase cannot make a new multiple dwellings relief claim.
- An earlier relief claim can, under HMRC’s guidance, separate a later part of the same deal.
- Without that earlier claim, linked-purchase rules can apply across the whole deal.
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 — tax calculation for a purchase that is not linked; tax calculation where purchases are linked
- FA 2003 section 81A — further return and payment after a later linked purchase
- FA 2003 section 108 — when purchases count as linked transactions
- FA 2003 section 116 — six or more homes treated as non-residential property
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
- The supplied HMRC page gives examples rather than a complete statement of every transitional case. Facts outside those examples need checking against the applicable transitional legislation.
- Whether purchases form one scheme, arrangement or series can be fact-sensitive, even where the same buyer and seller are involved.
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 any side agreements showing whether the purchases were one deal.
- Completion statements and dates for every part of the purchase.
- The original SDLT returns and any multiple dwellings relief claim.
- A schedule showing each property, its use, and whether it includes a shop or other business space.
- The amounts paid for each part of the deal and any allocation between properties.
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 Linked property purchases 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 - tax calculation for a purchase that is not linked https://www.legislation.gov.uk/ukpga/2003/14/section/55/2025-11-17 - FA 2003 section 55 - tax calculation where purchases are linked https://www.legislation.gov.uk/ukpga/2003/14/section/55/2025-11-17 - FA 2003 section 81A - further return and payment after a later linked purchase https://www.legislation.gov.uk/ukpga/2003/14/section/81A/2025-11-17 - FA 2003 section 108 - when purchases count as linked transactions https://www.legislation.gov.uk/ukpga/2003/14/section/108/2025-11-17 - FA 2003 section 116 - six or more homes treated as non-residential property https://www.legislation.gov.uk/ukpga/2003/14/section/116/2025-11-17 HMRC's guidance page on this topic (guidance, not law): https://www.gov.uk/hmrc-internal-manuals/stamp-duty-land-tax-manual/sdltm29904 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 - The supplied HMRC page gives examples rather than a complete statement of every transitional case. Facts outside those examples need checking against the applicable transitional legislation. - Whether purchases form one scheme, arrangement or series can be fact-sensitive, even where the same buyer and seller are involved. 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 31 August 2026
Useful article? You may find it helpful to read the original guidance here: SDLT multiple dwellings relief: claims before 1 June 2024 can separate later linked purchases
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