Abolition of Multiple Dwellings Relief for SDLT from 1 June 202

Multiple Dwellings Relief after abolition: transitional rules for contracts exchanged by 6 March 2024

Multiple Dwellings Relief (MDR) was abolished for SDLT transactions with an effective date on or after 1 June 2024, but it can still be claimed in some cases where the contract was exchanged on or before 6 March 2024. This protection only applies if the transaction is not treated as an excluded transaction, and the SDLT return must include both the exchange date and the completion date.

• MDR may still be available after 1 June 2024 if the contract was entered into on or before 6 March 2024 and the deal otherwise qualified for the relief.
• The protection is lost if, after 6 March 2024, the contract is varied, rights under it are assigned, an option or pre-emption right is exercised, or a sub-sale type arrangement changes who can call for the transfer.
• If the transaction becomes excluded, MDR is only preserved if completion took place before 1 June 2024.
• An early exchange date on its own is not enough; parties must check carefully whether any later changes or restructuring affect the contract or purchaser’s rights.
• HMRC says the SDLT return must show the exchange date as well as the completion date, or the MDR claim will be rejected.
• In practice, buyers and conveyancers should review the contract and any later variations, side letters, assignments, nominations, or supplemental agreements.

Scroll down for the full analysis.

Multiple Dwellings Relief after its abolition: contracts exchanged on or before 6 March 2024

This page explains when Multiple Dwellings Relief (MDR) can still be claimed for SDLT even though the relief was abolished for transactions with an effective date on or after 1 June 2024. The key point is that some transactions are protected by transitional rules if the contract was entered into on or before 6 March 2024. But that protection is lost in certain situations, so the detail matters.

What this rule is about

MDR was a relief that could apply where a purchaser acquired more than one dwelling in a single transaction or linked transactions. The source material deals with the transitional position after MDR was abolished.

The basic problem is this: a buyer may have exchanged contracts before the abolition took effect, but completion may happen later. The transitional rule decides whether that earlier contract preserves access to MDR.

This matters because SDLT is normally determined by the effective date of the transaction, which is usually completion. Without a transitional rule, a transaction completing on or after 1 June 2024 would generally no longer benefit from MDR.

What the official source says

According to HMRC’s SDLT manual, MDR is abolished for land transactions with an effective date on or after 1 June 2024.

However, MDR remains available where:

• the contract for the transaction was entered into on or before 6 March 2024, and
• the transaction is not an excluded transaction.

If those conditions are met, MDR can still be claimed even if completion takes place on or after 1 June 2024.

HMRC also says that a purchaser relying on this rule must include the date of exchange, as well as the date of completion, on the SDLT return. If the exchange date is not included, the MDR claim will be rejected.

The transaction becomes an excluded transaction if, after 6 March 2024:

• the contract is varied, or rights under it are assigned,
• the transaction is effected as a result of exercising an option, right of pre-emption, or similar right, or
• there is an assignment, sub-sale, or other dealing with all or part of the subject matter of the contract so that someone other than the original purchaser becomes entitled to call for a conveyance.

Where one of those exclusions applies, the transaction must complete before 1 June 2024 to remain eligible for MDR.

What this means in practice

The transitional rule gives protection to some pre-6 March 2024 deals, but only if the deal stays materially the same and is not caught by one of the listed exclusions.

In practical terms, there are two broad categories.

First, if contracts were exchanged on or before 6 March 2024 and nothing happens afterwards that makes the transaction excluded, MDR can still be available even if completion is on or after 1 June 2024.

Second, if there is a relevant post-6 March 2024 change or restructuring, the transitional protection is lost. In that case, the transaction only remains eligible if it actually completed before 1 June 2024.

This means parties should not assume that an early exchange date is enough on its own. They also need to check whether anything happened after 6 March 2024 that changes the contract position or the identity of the person entitled to complete.

It also means the SDLT return needs to be completed carefully. HMRC expressly requires the exchange date to be included where the purchaser is relying on this transitional rule.

How to analyse it

A sensible way to analyse the position is to ask these questions in order:

1. Would MDR have been available on the underlying facts apart from the abolition? The transitional rule only preserves MDR where it would otherwise have applied.
2. Was the contract entered into on or before 6 March 2024? If not, the transitional rule does not help.
3. Is the transaction an excluded transaction? Check carefully for any variation, assignment of rights, exercise of an option or pre-emption right, or sub-sale type arrangement after 6 March 2024.
4. If it is not excluded, completion after 1 June 2024 does not prevent MDR.
5. If it is excluded, did completion occur before 1 June 2024? If not, MDR is no longer available.
6. Has the SDLT return recorded both the completion date and the exchange date? HMRC says the claim will otherwise be rejected.

For conveyancers and taxpayers, the practical documents to review will usually include the signed contract, any side letters or supplemental agreements, any deed of variation, any nomination or assignment documentation, and any arrangements that alter who is entitled to call for the transfer.

Example

Illustration: a buyer exchanges contracts on 4 March 2024 to buy two dwellings in a transaction that would otherwise qualify for MDR. Completion takes place on 4 June 2024.

If nothing happened after exchange to vary the contract, assign rights, or otherwise make the transaction excluded, MDR can still be claimed despite the June completion date.

But if the contract was varied on 4 April 2024, for example to change the purchase price, HMRC’s published view is that the transaction becomes excluded. In that situation, the transaction would only remain eligible for MDR if it had completed before 1 June 2024. A completion on 4 June 2024 would be too late.

Why this can be difficult in practice

The main difficulty is working out whether something that happened after 6 March 2024 counts as a variation of the contract or another excluded event.

Some changes will be obvious, such as a formal deed changing the purchase price. Other cases may be less clear, especially where parties make amendments that they see as minor or administrative. The source material does not give a full test for what counts as a variation, so the legal effect of the change may need careful review.

There can also be difficulty where a transaction has been restructured between exchange and completion. For example, if rights are reassigned within a group or if a sub-sale arrangement is introduced, the question is not just what the parties intended commercially, but whether someone other than the original purchaser became entitled to call for the conveyance.

Another practical trap is return completion. A purchaser may be substantively entitled to rely on the transitional rule but still face rejection if the exchange date is omitted from the SDLT return.

The source material is HMRC guidance rather than the legislation itself, but it gives HMRC’s stated approach to these transitional rules and how claims will be handled in practice.

Key takeaways

• MDR was abolished for SDLT transactions with an effective date on or after 1 June 2024, but some earlier contracts are protected.
• If the contract was entered into on or before 6 March 2024 and the transaction is not excluded, MDR can still be available even if completion is after 1 June 2024.
• Post-6 March 2024 variations, assignments, option-style completions, and certain sub-sale arrangements can remove that protection, and the exchange date must be shown on the SDLT return.

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 1 June 202

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