Why would HMRC reject an SDLT authorisation?

Introduction

People often search for this issue after trying to appoint someone to deal with HMRC on a Stamp Duty Land Tax matter, only to find that HMRC says the authorisation has not been accepted. That can be frustrating, especially where a refund claim, amendment or enquiry response depends on an adviser being properly authorised.

In general, if HMRC does not accept an authorisation, the problem is usually procedural rather than substantive. It often means HMRC could not match the authority to the correct taxpayer or transaction, or the form of authority did not meet HMRC’s requirements.

The Question

A taxpayer was trying to authorise a representative to deal with HMRC in relation to an SDLT matter. HMRC did not accept the authorisation. The issue is what this usually means and what should be checked next.

Nick’s Explanation

Nick’s key point was simple: HMRC had not accepted the authority that had been submitted. In practical terms, that usually means the representative is not yet recognised by HMRC as authorised to act on the taxpayer’s behalf for that matter.

Where this happens, the next step is usually to review the authorisation method used, check the taxpayer details and transaction details carefully, and resubmit in the format HMRC expects.

The Law

HMRC will only discuss a taxpayer’s SDLT affairs with an agent or other representative if it is satisfied that the person has authority to act. That is part of HMRC’s general duty to protect taxpayer confidentiality and to deal only with properly authorised persons.

For SDLT, this is usually handled through HMRC’s recognised agent authorisation processes or by a clear written authority that HMRC is willing to accept for the specific matter in question. The exact route depends on the type of SDLT issue involved, such as a return, amendment, repayment claim or correspondence about an enquiry.

In practice, HMRC may reject or fail to process an authority where:

• the taxpayer’s name does not match HMRC’s records;
• the property transaction details are incomplete or inconsistent;
• the SDLT unique transaction reference or other identifying information is wrong;
• the authority is signed by the wrong person;
• the authority is unclear about the scope of representation;
• HMRC requires a different authorisation route for that type of matter.

Analysis

If HMRC says an SDLT authorisation has not been accepted, the first point is to distinguish between two different problems.

One possibility is that HMRC has received the authority but rejected it because the details do not match its records. For example, the taxpayer’s legal name may have been entered differently from the SDLT return, or the transaction reference may be incorrect.

The other possibility is that the wrong authorisation process was used. HMRC does not always accept the same form of authority for every tax or every type of SDLT issue. A general authority may not be enough for a particular repayment claim or dispute if HMRC expects a more specific form of authorisation.

It is also important to check who the taxpayer legally is. In SDLT matters, that may be an individual buyer, joint purchasers, trustees, a company, or a partnership. If the authorisation is not given by the correct legal person, HMRC may refuse to deal with the representative.

Where there are joint purchasers, HMRC may require authority from each relevant taxpayer, depending on the issue. If a company is involved, the authority may need to come from a properly authorised officer or agent using the correct company details.

Another common issue is simple document quality. If the authority was scanned poorly, partly cut off, unsigned, undated, or otherwise unclear, HMRC may not process it.

Outcome

The practical conclusion is that HMRC’s refusal to accept the authorisation does not necessarily mean there is anything wrong with the underlying SDLT position. It usually means HMRC is not satisfied that the representative is properly authorised to act.

Until that is fixed, HMRC may refuse to discuss the case, process requests through the representative, or provide updates on the matter.

Practical Steps

• Check the taxpayer’s full legal name against the SDLT return and HMRC records.
• Check the transaction details carefully, including the effective date, property details and any SDLT transaction reference.
• Make sure the authority is signed by the correct person or persons.
• Confirm whether HMRC requires a specific SDLT authorisation route for the matter.
• Resubmit the authority in a clear and complete form.
• If the matter is urgent, ask HMRC what exactly was wrong with the previous authorisation so the defect can be corrected.
• Keep copies of the authority submitted and any HMRC response.

Conclusion

If HMRC did not accept an SDLT authorisation, the usual answer is that the representative has not yet been properly recognised to act. The solution is normally to check the taxpayer identity, transaction details, signature authority and submission method, then submit the authority again in the format HMRC requires.

Legal References Used

• HMRC practice on agent and taxpayer authorisation for dealing with tax affairs
• Stamp Duty Land Tax administrative requirements under HMRC procedures

This page was last updated on 22 March 2026.

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