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MDR has been abolished for transactions which complete, or which substantially perform (see SDLTM07850), on or after 1 June 2024, subject to special transitional rules (see SDLTM29902+.).

Special transitional rules relating to linked transactions, can be found at SDLTM29903

Where:

• relief is claimed under FA03/SCH6B for a relevant transaction,
• during a period following the effective date of the transaction(s) (the “relevant periodâ€�) an event occurs and
• if that event had occurred, immediately before the effective date, more tax would have been payable, either because the transaction would not have been a relevant transaction or otherwise then tax is chargeable on the transaction as if the event took place immediately prior to the effective date of the transaction.

For this purpose, “event� includes any change of circumstance or change of plan but does not include an onward sale of individual dwellings.

This provision may be triggered where

• the subject-matter of the transaction ceases to include dwellings (so that the transaction ceases to be a relevant transaction), or where
• the number of dwellings included in the subject-matter of the transaction is reduced (for example by combining smaller dwellings into larger ones).

»Ê¹ÚÌåÓýapp relevant period is:

• the period ending three years after the effective date of the transaction or, in respect of a dwelling,
• the date on which the purchaser disposes of that dwelling to a person who is not connected with him.

In the case of a transaction substantially performed before completion, the relevant period runs from the date of substantial performance.

»Ê¹ÚÌåÓýapp recalculation of the tax due is based on the whole of the consideration given for the subject-matter of the transaction and the number of dwellings following the event, including any dwellings sold on prior to the event.

Where the result of a recalculation following an event is that more tax is due, the purchaser must make a further return and pay the additional tax within 30 days of the event.

Further returns should be made by letter to the Birmingham Stamp Office

References in FA03/SCH10 to the effective date of the transaction are to be read as references to the date of the event. »Ê¹ÚÌåÓýapp tax chargeable is calculated by reference to the rates in force at the effective date of the transaction.