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HMRC internal manual

Stamp Duty Land Tax Manual

Reliefs for transfers involving multiple dwellings: Example 9

The transaction is a relevant transaction as it involves the acquisition of a total of 13 dwellings - the mansion, the flats and the houses.

The mansion, stable block and gardens are treated as part of a single dwelling. The consideration attributed to dwellings is £8 million and the remaining consideration attributed to the farm buildings and farmland is £4 million.

The rate of tax on the dwellings consideration is set by the amount of that consideration, divided by the number of dwellings. £8 million divided by 13 is £615,385 so the rate of tax is 4%. The rate of tax on the remaining consideration of £4 million is also 4% as the farm buildings and farmland are non-residential property and the transaction as a whole is a “mixed” transaction, so the non-residential scale of rates applies.

The whole transaction is therefore taxed at 4%. This is no different from the rate which would apply in the absence of the relief, so relief is not claimed.