HMRC has launched an enforcement campaign targeting tax agents who claim repayment of stamp duty land tax (SDLT) because the property needs extensive repairs, is uninhabitable, and therefore not liable to residential SDLT. HMRC’s stance is based on the recent England and Wales Court of Appeal decision in Mudan v HMRC (2025 EWCA Civ 799), which agreed with both tax tribunals that dwellings needing repair remain chargeable to residential rates of SDLT. HMRC has described Mudan as ‘a major win protecting public funds’.
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