Malcolm Finney looks at the recent stamp duty land tax case Mudan & Anor v HMRC [2025] EWCA Civ 799.â¯
Stamp duty land tax (SDLT) is a tax which applies to land transactions, i.e., the acquisition of a chargeable interest. A chargeable interest is, broadly, an estate or interest in land.
Any SDLT liability on an acquisition is that of the purchaser. The amount of SDLT chargeable is based on the quantum of chargeable consideration in relation to the acquisition.
Residential versus non-residential land
There are a variety of rates possibly applicable, but with a critical difference between the rates applicable to a land transaction comprising residential land versus a land transaction comprising non-residential land (FA 2003, s 55, 
