MDR

‘Overpayment relief is a statutory remedy of last resort.’ Helen Coward (Simmons & Simmons) examines when HMRC can refuse SDLT repayment claims – and when they cannot.

Property not two dwellings at time of acquisition for MDR purposes

Dwelling for SDLT purposes: In Shinebrook Ltd v HMRC [2026] UKFTT 602 (TC) (16 April), the FTT ruled that Multiple Dwellings Relief (MDR) from SDLT was not available in relation to the purchase of a former commercial property, on which planning...

Upper Tribunal denies SDLT overpayment relief

SDLT MDR denied where planning restriction existed.

SDLT pre-completion transactions and substantial performance: There are several complexities in G Goldsmith Ltd and another v HMRC [2024] UKFTT 927 (TC) (18 October) of interest to SDLT practitioners. It also shows some of the dangers which arise...

SDLT MDR claim denied: Shine Business Ltd v HMRC [2024] UKFTT 894 (TC) (7 October) is another in the long line of cases on the now-abolished SDLT multiple dwelling relief. Like all such appeals the decision is highly fact dependent. The FTT,...

MDR appeal allowed.

Application to strike out MDR claim rejected: HMRC has had a high level of success in appeals involving multiple dwelling and mixed used SDLT reliefs. In Newsand Ltd v HMRC [2024] UKFTT 221 (TC) (13 March 2024), HMRC sought to build on those...