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Multiple Dwellings Relief (MDR)

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Multiple Dwellings Relief (MDR)

Ted, a property developer, is planning to purchase a block of 10 flats for a total consideration of £900,000 and has queried the SDLT position. The flats will be purchased by his limited company, Ted Developments Limited.

Considerations:

 

  • As Ted Developments is purchasing from the same vendor as part of one deal, the transaction will be considered to be a ‘linked transaction’ and therefore the total consideration is aggregated.

  • The super rate of 15% associated with companies purchasing high value residential property will not be applied as no individual property exceeds the threshold of £500,000.

  • The 3% surcharge will be applied as it is a corporate purchase.

  • On first principles, if the Table A rates (residential) are applied along with the 3% surcharge, the SDLT payable would be £62,000.

  • However, the legislation specifically provides that where 6 or more dwellings are purchased, they will not be treated as residential property. Accordingly, the rates at Table B (non-residential) should be applied, resulting in the total tax payable of £34,500.

  • Moreover, a claim for Multiple Dwellings Relief (MDR) could be claimed as more than 2 properties are being purchased. If MDR is claimed, the above rule of using Table B is disapplied, so that Table A (using the 3% surcharge) is applied to the average price of each flat and this figure is then multiplied by the number of flats. A claim for MDR would result in SDLT payable of £27,000.

 

Following our advice, the company made a claim for MDR and needless to say Ted was a very happy developer!
 

If you have any queries around SDLT please do not hesitate to get in contact via our SDLT Advisory Service.

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