The purchase of a property comprised an interest in at least two dwellings, which were used or suitable for use as a single dwelling, such that stamp duty land tax multiple dwellings relief was available on the transaction. 

On 16 December 2021, the appellant purchased a residential property for £1.8m. The appellant considered that the property comprised two dwellings and submitted his stamp duty land tax (SDLT) return on the basis that multiple dwellings relief (MDR) was available. Following an enquiry, HM Revenue and Customs (HMRC) concluded that the property comprised a single dwelling, so no MDR was available. The appellant appealed. 

The First-tier Tribunal (FTT) noted that the property comprised two “dwellings”. Dwelling 2 (where the appellant’s family lived) comprised four bedrooms, two bathrooms, toilets, sitting room, dining room, kitchen and utility room, large hallway, and separate outside doors for access.