A property comprising a main house and annexe did not constitute two dwellings for stamp duty land tax multiple dwellings relief purposes.

The appellants (husband and wife) purchased a residential property in Gerrards Cross for £2,750,000. The effective date of transaction (EDT) for stamp duty land tax (SDLT) purposes was 1 August 2018. The husband filed an SDLT return (the first SDLT return) and self-assessed the SDLT to be £243,750. Subsequently, an accountancy firm (L) amended the first SDLT return by making a claim for multiple dwellings relief (MDR) which resulted in £81,250 being repayable to the appellants.<>