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One per cent muddle
Key points
- Clarification on how to calculate the liability in certain circumstances when 1% minimum under multiple dwellings relief (MDR) applies.
- Interaction between 1% minimum under MDR and other additional stamp duty land tax charges.
- Guidance is unclear but an informal opinion has confirmed HMRC’s view.
- Taxpayers may have overpaid liabilities.
Stamp duty land tax has gained a lot of attention of late from advisers and taxpayers alike. Its popularity is due to planning opportunities arising from a combination of the temporary holiday rates implemented between 8 July 2020 and 30 September 2021 and increased knowledge about various reliefs available.
It is one of the lesser-known taxes but it is gaining traction. In 2020 and 2021 there were an abundance of cases addressing uncertainties relating to an increasingly popular relief known as multiple dwellings relief (MDR). Historically a lack of case law and patchy guidance led...
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