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In Marcus and Marcus Limited v HMRC [2022] TC08476, the First Tier Tribunal (FTT) determined that the main property in an estate purchase qualified for Multiple Dwellings Relief and that the apportionment of consideration based on floor area was just and reasonable.

The FTT found that the value of the main house was under £500,000 so could be included in the MDR calculation:

Useful guides on this topic

SDLT: Stamp Duty Land Tax, start here
What is SDLT? What are the SDLT rates? What is exempt from SDLT? What reliefs are available? When are returns due? When can you amend a return?

SDLT: Multiple Dwelling Relief (MDR)
What is Multiple Dwellings Relief (MDR) for Stamp Duty Land Tax purposes? When does it apply and how is it claimed?

SDLT: MDR & Annexes Tool
Stamp Duty Land Tax (SDLT) Tool, if you are buying two or more properties in a single transaction use this tool to see if you meet the qualifying conditions and you may be able to claim both Multiple Dwellings Relief and relief from the Higher Rate Charge.

SDLT: Residential property & dwellings
What is residential property for Stamp Duty Land Tax (SDLT)? What tax rate applies?  What garden and grounds are subject to higher rates of SDLT?

External links

Marcus and Marcus Limited v HMRC [2022] TC08476


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