SDLT Changes: Spring Budget

March 12, 2024


Whilst it wasn’t the most exciting of Spring Budgets, given that most of the key announcements were teased in the media for many weeks leading up to the Chancellor’s budget day, there were still a few notable changes that will impact property investors.


Multiple Dwellings Relief

A consultation was held from 30 November 2021 to 22 February 2022 on 2 measures to improve the operation of SDLT. The 2 measures aimed to ensure fairer outcomes and reduce the scope for incorrect claims and abuse of the rules for:

  • ‘mixed-property’ transactions – purchases which consist of both residential and non-residential property
  • relief for purchases of 2 or more dwellings – known as ‘Multiple Dwellings Relief’ (MDR)

In February 2023 HMRC commissioned an external evaluation of MDR as part its Tax Reliefs Evaluation programme, the aim being to understand the extent to which MDR achieves its original policy aims. The outcome of the evaluation is published.

From 1 June 2024, Multiple Dwellings Relief (MDR) for Stamp Duty Land Tax will be abolished.

Contracts exchanged on or before March 6, 2024, will still qualify for MDR if not altered after that date. Transactions substantially completed on or before 1 June 2024, will also qualify. For transactions involving purchases before and after the change, MDR will not apply across both phases.

An unintended consequence of the abolition of SDLT MDR is to obliterate the competitive advantage of being a UK-resident buyer of 6+ dwellings in one deal.

A non-resident buyer generally was subject to the +3% and +2% surcharges, making a claim for MDR positively worse than the default position of just-less-than-5% under s116(7) FA03.

But a resident buyer could often keep their liability to 3% (or even less) with an MDR claim.

That advantage has made a material difference for UK-resident buyers in portfolio bids that I have seen.

Therefore, we might see a significant shift in the types of buyers purchasing multiple units.


Acquisitions by Registered Social Landlords and Public Bodies

The government will introduce legislation in Spring Finance Bill 2024 to amend out of date references and definitions in Stamp Duty Land Tax (SDLT) legislation relating to registered social landlords. The government will also introduce legislation to remove public bodies from the SDLT 15% higher rate charge when purchasing residential property with a value of more than £500,000. These changes will take effect from 6 March 2024.


First-time Buyers’ Relief: Leases and Nominees

The government will introduce legislation in Spring Finance Bill 2024 amending the rules for claiming First-time Buyers’ Relief from Stamp Duty Land Tax.

The changes will mean that individuals who purchase new leases using nominee or bare trust arrangements will be able to claim the relief and ensure that individuals who have used such arrangements in the past are unable to claim the relief on future purchases made in their own name.

The changes will take effect from 6 March 2024. Where contracts are exchanged on or before 6 March 2024, transitional rules may apply subject to conditions.


Get in Touch

For more information on how you can maximise your tax savings and plan your next property investment around the reliefs available, then please speak to our tax experts. Call us on 020 3523 9125 or email

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