Lee Sharpe looks at stamp duty land tax and the application of the 3% ‘surcharge for additional dwellings’ where the transaction involves both several dwellings and non-dwellings.
Finance Act 2016 introduced a new Sch 4ZA into FA 2003, being the imposition of higher rates of stamp duty land tax (SDLT) for additional dwellings (commonly referred to as the 3% surcharge for additional dwellings) from 1 April 2016. There are areas of uncertainty with more complex transactions, and this article will cover a particular issue where HMRC has completely backtracked on its original position.
Note that the surcharge applies differently in Scotland and Wales. For simplicity (and longevity), this article has also ignored the special rates introduced temporarily to support homebuying during the pandemic.
