Abolition of Multiple Dwellings Relief for SDLT from June 2024

SDLT after the end of Multiple Dwellings Relief

Multiple Dwellings Relief (MDR) has been abolished for most Stamp Duty Land Tax transactions completing, or substantially performed, on or after 1 June 2024. Transitional rules may still preserve MDR where contracts were exchanged on or before 6 March 2024 and were not later varied. For single purchases of six or more dwellings, the separate rule treating the transaction as non-residential still applies.

• MDR is generally no longer available for transactions that complete or are substantially performed on or after 1 June 2024.
• MDR may still apply if contracts were exchanged on or before 6 March 2024, provided the contract was not varied after that date.
• The timing of completion, substantial performance and any later contract changes is critical to the SDLT outcome.
• Special transitional rules can affect linked transactions where some purchases took place before the law changed and some after it.
• If six or more dwellings are bought in a single transaction, Finance Act 2003 section 116(7) treats the purchase as non-residential for SDLT purposes.
• After the abolition of MDR, buyers of six or more dwellings can no longer choose between MDR and the non-residential treatment where MDR is unavailable.

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SDLT after the abolition of Multiple Dwellings Relief

This page explains what changed when Multiple Dwellings Relief, usually called MDR, was abolished for Stamp Duty Land Tax. The change matters because it affects how SDLT is calculated where a buyer acquires more than one dwelling, and it also changes the position for purchases of six or more dwellings in one transaction.

What this rule is about

MDR was a relief that could reduce SDLT where a transaction involved more than one dwelling. HMRC’s material here deals with the end of that relief and the transitional rules for transactions that were already in progress when the law changed.

The key legal question is timing. Whether MDR is still available depends mainly on when the transaction completed or was substantially performed, and in some cases when contracts were exchanged and whether the contract was later varied.

The material also addresses a separate but related rule in Finance Act 2003 section 116(7). That rule treats a single transaction for six or more dwellings as non-residential for SDLT purposes. Before MDR was abolished, a purchaser could in some cases choose between claiming MDR and relying on the six-or-more-dwellings rule. After abolition, that choice no longer exists where MDR is unavailable.

What the official source says

HMRC states that MDR is abolished for transactions that complete, or are substantially performed, on or after 1 June 2024.

There is an important saving rule. If contracts were exchanged on or before 6 March 2024, MDR can still be available even if completion happens later, provided the contract is not varied after that date. HMRC refers to separate guidance on those transitional provisions.

HMRC also says there are special rules for linked transactions where some purchases of dwellings happened before the change and some after it. In broad terms, if MDR was claimed for the pre-change transaction or transactions, the later post-change transaction or transactions are treated as no longer linked to them for this purpose.

On purchases of six or more dwellings in a single transaction, HMRC explains that before abolition the purchaser could choose either MDR or the rule in Finance Act 2003 section 116(7), which treats the transaction as non-residential. Once MDR is no longer available, there is no longer any such choice. In a single transaction for six or more dwellings, section 116(7) applies and the transaction is treated as non-residential.

What this means in practice

The first practical point is that MDR is not generally available for transactions completing or substantially performing on or after 1 June 2024. If a buyer was expecting to use MDR, the timing of the transaction now becomes critical.

The second point is that exchange of contracts can still preserve access to MDR, but only in a defined class of cases. The contract must have been exchanged on or before 6 March 2024, and there must not have been a variation after that date. If there was a later variation, the transitional protection may be lost. Whether a change counts as a variation is therefore potentially important.

The third point is that linked transactions need careful review. Linked transaction rules can affect the SDLT calculation by aggregating consideration across transactions. HMRC’s transitional approach means that where MDR was claimed on an earlier pre-change transaction, later post-change transactions may be treated as not linked to those earlier ones. That can change the SDLT position materially, so a buyer or adviser should not assume the usual linked transaction treatment applies unchanged across the legislative change.

The fourth point is that large portfolio or block purchases of six or more dwellings still have a specific statutory treatment. If six or more dwellings are bought in a single transaction, Finance Act 2003 section 116(7) treats that transaction as non-residential. Since MDR has been abolished for the relevant post-change transactions, the purchaser cannot instead choose MDR. The non-residential treatment follows from the statute.

How to analyse it

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

• Is this an SDLT transaction involving more than one dwelling?
• Did the transaction complete before 1 June 2024, or was it substantially performed before that date?
• If not, were contracts exchanged on or before 6 March 2024?
• If contracts were exchanged by that date, was the contract varied afterwards?
• Is the transaction part of a set of linked transactions spanning both sides of the rule change?
• If so, was MDR claimed on the pre-change transaction or transactions, so that the later transactions may be treated as no longer linked to them?
• Does the transaction involve six or more dwellings in a single transaction, so that Finance Act 2003 section 116(7) applies?

This framework matters because different timing and structuring facts can lead to different outcomes. In particular, it is not enough to know that a purchase involves multiple dwellings. You must also identify the relevant dates, whether there has been substantial performance, whether contracts were protected by the transitional rule, and whether the transaction stands alone or forms part of linked transactions.

Example

Illustration: A buyer exchanges contracts on 1 March 2024 to acquire three flats in one transaction, but completion takes place in July 2024. If the contract was not varied after 6 March 2024, HMRC’s guidance indicates that MDR can still remain available under the transitional rule, despite completion after 1 June 2024.

By contrast, if a buyer enters into a single transaction completing in July 2024 to acquire six dwellings, MDR is no longer available simply as a matter of choice. Instead, Finance Act 2003 section 116(7) applies so that the transaction is treated as non-residential for SDLT purposes.

Why this can be difficult in practice

The main difficulty is that the outcome depends on precise facts and dates.

One area of potential difficulty is substantial performance. HMRC’s page cross-refers to separate guidance on what counts as substantial performance. That can matter because the relevant date is not only completion; substantial performance before completion may also fix the SDLT treatment.

Another difficulty is contract variation. The transitional protection for pre-6 March 2024 exchanges depends on there being no variation after that date. Whether a later change is legally a variation, and whether it affects the saving rule, may require careful analysis of the contract history.

Linked transactions are another fact-sensitive area. The normal SDLT linked transaction rules are already technical, and the transitional rule adds another layer where some transactions occurred before abolition and others after it. HMRC’s guidance indicates that post-change transactions may be treated as no longer linked to earlier ones where MDR was claimed on the earlier transactions, but the exact application will depend on the facts.

There is also an important distinction between a transaction involving multiple dwellings and a single transaction for six or more dwellings. After abolition, the latter still falls within the statutory non-residential rule in section 116(7). That is not the same thing as MDR continuing in another form. It is a separate rule with its own effect.

Key takeaways

• MDR is abolished for transactions that complete or are substantially performed on or after 1 June 2024, subject to transitional protection for certain earlier exchanges.
• If contracts were exchanged on or before 6 March 2024, MDR may still be available, but only if the contract was not varied after that date.
• For a single transaction involving six or more dwellings, Finance Act 2003 section 116(7) now applies without any alternative choice of MDR where MDR is no longer available.

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 from June 2024

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