SDLT linked transactions – what property investors must know

If you’re buying multiple properties from the same seller, the rules on SDLT linked transactions could dramatically increase your tax bill.

These rules apply when two or more property transactions involve the same buyer and seller (or connected persons) and form part of one arrangement or a series of linked deals.

Here’s a detailed breakdown of how the SDLT linked transactions rules work in England and Northern Ireland — updated for 2025/26 — plus how you can mitigate risk and when to get expert help.

1. When do the SDLT linked transactions rules apply?

  • If you (or someone connected to you) buy more than one property from the same seller and the deals are part of a single scheme or arrangement, they are linked.

  • If you make a series of purchases from the same seller, even over time, they may be linked transactions. There is no time limit on how long after the first deal the later deals may trigger linkage

  • “Connected persons” include relatives, spouses, corporate affiliates, companies under common control, and so on. The rules treat them as the same buyer/seller for linkage.

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If these criteria are met, you’re dealing with SDLT linked transactions and must base SDLT on the total value of all those linked deals, not just each individually.

2. How are taxes calculated under SDLT linked transactions?

Single arrangement

When multiple properties are acquired as part of one single deal (for example, several units bought from a developer under one agreement), you must calculate SDLT on the aggregate consideration.

Paying for each separately does not avoid the linkage.

You apply the residential or non-residential rates depending on the nature of the properties.

Series of transactions

If you buy multiple properties from the same seller at different times, the linked-transaction rules still apply.

At each new purchase you must:

  1. Combine the total chargeable consideration of all linked deals to date.

  2. Calculate SDLT on that amount according to the correct rate table (residential + any surcharge, or non-residential).

  3. Apportion the total SDLT liability across each property by reference to its share of the total consideration.

  4. If you’ve already paid SDLT on an earlier linked purchase, you may need to pay additional SDLT at the later event to bring the earlier purchase up to where it should have been under the combined calculation.

Residential vs Non-residential

  • If all the linked properties are residential dwellings, use the residential SDLT rates (including any additional property surcharge).

  • If any one (or more) of the linked properties is non-residential (or mixed-use), then the non-residential SDLT rate table applies to all the linked transactions.

3. What’s changed for 2025/26 (important for SDLT linked transactions planning)

  • The primary residential nil-rate band remains as updated from 1 April 2025. GOV.UK+1

  • The higher rate surcharge (for additional residential properties) was increased from 3% to 5% on or after 31

  • The special higher rate for non-natural persons (companies, etc) purchasing residential property (often referred to as the ATED-related SDLT charge) increased from 15% to 17%.

  • Multiple Dwellings Relief (MDR) has been abolished for transactions with an effective date on or after 1 June 2024. That means MDT cannot mitigate SDLT for linked transactions after that date.

In short: when you’re dealing with SDLT linked transactions, you must assume all the aggregated value of deals will be taxed at the newer, higher surcharge rates — and you cannot rely on MDR to reduce the liability for multi-dwelling purchases.

4. Why does understanding SDLT linked transactions matter for property investors?

  • If you buy multiple properties from the same seller without recognising the linkage, you may end up paying substantially more SDLT than anticipated.

  • A small discount per unit or separate contracts might trigger linkage, causing the full aggregated value to fall into higher SDLT bands.

  • Later purchases can trigger top-up SDLT liability on earlier deals (via apportionment) — so what you paid initially may increase.

  • Planning ahead is essential: structuring how and when you buy, from whom, how many units, and how each contract is drawn can make a big difference.

  • For investors with multiple purchases, ignoring the SDLT linked transactions rules is a material risk.

5. How Trueman Brown can help you

When it comes to dealing with the complexities of SDLT linked transactions, Trueman Brown offers specialist support.

We can assist you with:

  • Reviewing your purchase contracts and structure to identify whether linkage may apply.

  • Calculating your best-case and worst-case SDLT outcomes under linked transaction rules.

  • Advising on timing, contract terms, seller-buyer relationships and connected-person issues.

  • Preparing SDLT returns, top-up calculations for earlier deals, and liaising with HM Revenue & Customs on linked-transaction disclosures.

Contact us for a tailored review:
📧 mark@truemanbrown.co.uk
📞 01708 397262

It’s wise to engage early — particularly if you are buying multiple properties from the same seller (or likely to do so). This ensures you plan for the impact of SDLT linked transactions rather than discovering a surprise tax bill later.

6. FAQ

Q1. What exactly counts as a “linked transaction”?
A1. When two or more property transactions are between the same buyer and seller (or people connected to them) and are part of one arrangement or series of deals.

Q2. Is there a time limit between linked deals?
A2. No. The linkage rules can apply regardless of how much time passes between the first and later transactions.

Q3. If I buy from the same seller but with no “special discount” or linked contract, am I safe?
A3. Possibly, but you should be careful. HMRC may scrutinise whether the transactions are genuinely separate or part of a linked scheme. The existence of a special price or arrangement is a common indicator of linkage.

Q4. If one of the linked properties is non-residential, how does that affect SDLT?
A4. If any of the linked properties is non-residential (or mixed-use), then the non-residential SDLT rate table will apply to all the linked transactions.

Q5. Does the abolition of MDR affect linked transaction situations?
A5. Yes. Because MDR (Multiple Dwellings Relief) is no longer available for transactions with effective dates on or after 1 June 2024, you cannot rely on MDR to reduce SDLT in linked-transaction cases from that date onwards.

Q6. What should I do if I’m unsure whether my deals are “linked”?
A6. Seek specialist advice (such as from Trueman Brown). Review contract dates, seller relationships, pricing/discount structure, whether the seller is the same entity, and the connected-person status. Early review can save significant SDLT.