Shine Business Limited purchased a £1.9m property with six bedrooms, garden and a swimming pool and jacuzzi in Purley on 28 January 2022 with the purpose of letting the house out as two separate dwellings.

The company’s then representative filed a land transaction return on 28 February 2022. The return showed a liability to stamp duty land tax (SDLT) of £198,750.

After the first SDLT return, Shine hired a different company, Cornerstone Tax to handle his return, and on 24 March 2022 the new agent wrote to HMRC to amend the return and claim a £64,250 SDLT refund.

Cornerstone claimed that the property consisted of two separate dwellings so multiple dwellings relief (MDR) was applicable. The letter explained that, at the time the return had been filed, Shine did not know that MDR ‘was available to them’.

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