What is the stamp duty multiple dwellings relief?
Answered 11 March 2026
I now have sufficient information to provide a comprehensive answer. Here is a full explanation of the SDLT Multiple Dwellings Relief (MDR):
SDLT Multiple Dwellings Relief (MDR)
⚠️ Important: MDR has been abolished for transactions with an effective date on or after 1 June 2024. The information below describes the relief as it applied before that date, and may still be relevant for transactions that fall within the transitional rules.
What the law says
Statutory basis
MDR was provided for by section 58D and Schedule 6B of the Finance Act 2003 (FA 2003). Section 58D stated:
"Schedule 6B provides for relief in the case of transfers involving multiple dwellings. Any relief under that Schedule must be claimed in a land transaction return or an amendment of such a return."
Qualifying transactions
The relief applied to a chargeable transaction where its main subject-matter consisted of:
- (a) an interest in at least two dwellings, or
- (b) an interest in at least two dwellings and other property.
How the relief was calculated
Under paragraph 4 of Schedule 6B, the effect of MDR was to lower the effective rate of SDLT by:
- Dividing the chargeable consideration by the number of dwellings;
- Applying the applicable residential rates (under s.55 FA 2003) to that average amount to establish the SDLT charge per dwelling; and
- Multiplying that amount by the number of dwellings to calculate the total SDLT chargeable.
A minimum charge of 1% of the total consideration applied if the calculated amount fell below that threshold.
What counts as a "dwelling"
Paragraph 7(2) of Schedule 6B defined a dwelling as a building or part of a building that:
- (a) is used or suitable for use as a single dwelling, or
- (b) is in the process of being constructed or adapted for such use.
Land occupied or enjoyed with a dwelling as garden or grounds is treated as part of that dwelling (para 7(3)).
Abolition
Section 7(1) of the Finance (No. 2) Act 2024 repealed section 58D and Schedule 6B in their entirety. The repeal has effect for land transactions with an effective date on or after 1 June 2024.
Transitional protection exists where:
- The transaction is effected pursuant to a contract entered into and substantially performed before 1 June 2024, or
- The contract was entered into on or before 6 March 2024 (and not subsequently varied or assigned).
HMRC guidance / practice
How HMRC explained the relief
HMRC confirmed that MDR "has been abolished for transactions which complete, or which substantially perform, on or after 1 June 2024" and that guidance on MDR "is only applicable to transactions with an effective date prior to 1 June 2024."
Practical example (HMRC)
HMRC illustrated the calculation as follows: a company purchasing a block of 10 flats for £1,000,000 would pay SDLT of £30,000 under MDR (average consideration of £100,000 × 3% × 10 flats), compared to £39,500 under non-residential rates.
Six or more dwellings
Where six or more dwellings were purchased in a single transaction, the purchaser had a choice: claim MDR (paying higher residential rates on the averaged consideration) or apply the non-residential rates under s.116(7) FA 2003. Now that MDR is abolished, s.116(7) applies automatically to such transactions.
Meaning of "suitable for use as a single dwelling"
The Upper Tribunal in Fiander and Brower v HMRC [2021] UKUT 156 held that "suitable" means the property must be appropriate or fit for use as a single dwelling at the effective date — it is not enough that it could be made fit by future adaptations or alterations. The existence of paragraph 7(2)(b) (covering properties in the process of being adapted) strongly implies that a property not yet being adapted does not qualify under paragraph 7(2)(a).
Claim requirement
HMRC's position (confirmed in case law) is that MDR must be actively claimed in a land transaction return or an amendment to one — it is not applied automatically.
Citation sources
Measures relating to property Abolition of multiple dwellings relief for SDLT 7 1 Section 58D of, and Schedule 6B to, FA 2003 (relief for transfers involving multiple dwellings) are repealed. 2 In consequence of the repeal of those provisions— a in Part 4 of FA 2003— i in section 87(3) (interest on unpaid tax: meaning of “relevant date”), omit paragraph (aza), ii in Schedule 4A (higher rates for certain transactions), in paragraph 2(6), omit paragraph (d) and, in paragraph 7, for sub-paragraph (
Part 4 Stamp duty land tax Reliefs Transfers involving multiple dwellings 58D 1 Schedule 6B provides for relief in the case of transfers involving multiple dwellings. 2 Any relief under that Schedule must be claimed in a land transaction return or an amendment of such a return.
Multiple Dwelling Relief (MDR) has been abolished for transactions which complete, or which substantially perform (see SDLTM07850), on or after 1 June 2024. However, purchasers who exchanged contracts on or before 6 March 2024 remain eligible for MDR regardless of when the transaction completes, provided there is no variation of the contract after that date (see SDLTM29902). There are transitional rules for transactions which are linked (see SDLTM30100) and include the purchase of dwellings both
case. 12. The material parts of paragraph 7 of schedule 6B, under the sub-heading ‘What counts as a dwelling’, provided: (1) This paragraph sets out rules for determining what counts as a dwelling for the purposes of this Schedule. (2) A building or part of a building counts as a dwelling if— (a) it is used or suitable for use as a single dwelling, or (b) it is in the process of being constructed or adapted for such use. 13. Schedule 6B was considered by the Upper Tribunal (Judge Thomas Scott an
3 (1) A chargeable transaction to which this Schedule applies is referred to in this Schedule as a “relevant transaction”. (2) ... (4) A relevant transaction is a “multiple dwelling transaction” if its main subject-matter consists of— (a) an interest in at least two dwellings, or (b) an interest in at least two dwellings and other property. (5) In relation to such a transaction, those dwellings are referred to as “the dwellings”. 39. Paragraph 4 of Schedule 6B provides for the calculation of rel
Section 58D provided as follows: 58D Transfers involving multiple dwellings (1) Schedule 6B provides for relief in the case of transfers involving multiple dwellings. (2) Any relief under that Schedule must be claimed in a land transaction return or an amendment of such a return. (9) Paragraph 1(c) of Schedule 6B states that “paragraphs 4 and 5 describe the relief available if a claim is made”. (10) Paragraph 2 of Schedule 6B provides: 2 Transactions to which this Schedule applies (1) This Sched
der which an application could be made to discharge or vary the Planning Condition. No such application has been made. The Law 20. The law on SDLT is primarily set out in Part 4 the Finance Act 2003 (“FA 2003”). It is unnecessary to set out most of the legislative material at length, the key points are: (1) SDLT is charged on a land transaction under s 42 of FA 2003. (2) This means any acquisition of a ‘chargeable interest’ under s 43 of FA 2003, providing it is not a transaction which is exempt
d reasonable basis, is £500,000 or less, HMRC accept that MDR can apply to all three dwellings and Mr Cannon calculates the correct SDLT on that basis as £13,749. 50. There are two questions: (1) What constitutes each of the “dwellings”? (2) Having established what is comprised in each dwelling, what is a just and reasonable apportionment of the consideration between them? 51. Paragraph 7 of Schedule 6B sets out “What counts as a dwelling”: “7 (1) This paragraph sets out rules for determining wh
Read Full Decision THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS v DANIEL RIDGWAY STAMP DUTY LAND TAX – mixed use property – section 116 Finance Act 2003 – suitable for use as a dwelling – relevance of covenant in a lease not to use the premises for residential purposes – relevance of planning law restrictions – whether the FTT failed to take into account all relevant factors – enquiry into land transaction return – HMRC concluding that not mixed use property – absence of any claim for
d transaction were as follows: So much as does not exceed £250,000 - 0% So much as exceeds £250,000 but does not exceed £925,000 - 5% So much as exceeds £925,000 but does not exceed £1,500,000 - 10% The remainder (if any) 12% 15. Section 58D introduces Schedule 6B which provides for MDR, the effect of which, as set out in paragraph 4 of Schedule 6B, is to lower the effective rate of SDLT by dividing the chargeable consideration by the number of dwellings which are the subject matter of a land tr
· Multiple dwellings relief (“MDR”) has been abolished for transactions which complete, or which substantially perform, on or after 1 June 2024. · This guidance is only applicable to transactions with an effective date prior to 1 June 2024. Where two or more dwellings are purchased in a single or linked transaction multiple dwellings relief (FA2003/Schedule 6B) can be claimed. Where six or more dwellings are purchased in a single transaction, the purchaser can choose whether to apply the non-r