An SDLT enquiry is a formal review by HMRC of a Stamp Duty Land Tax return. HMRC normally has nine months from the filing date to start a compliance check, but longer periods can apply in some circumstances. We check the relevant dates and the basis of the letter rather than assuming an enquiry is out of time. An enquiry does not automatically mean something is wrong with the return. It means HMRC wants to examine the position more closely. However, how you respond to the enquiry determines how it proceeds, and an early, well-prepared response makes a significant difference to the timeline and outcome.
HMRC focuses its SDLT enquiry resources on areas where incorrect treatment is most common and the revenue at stake is highest. Common triggers include: mixed-use SDLT claims, particularly where the non-residential element is marginal; relief claims on company purchases, including whether the conditions for relief from the higher rate for certain corporate purchases were met; linked transactions where the connection between purchases has not been properly reflected in the SDLT computation; and unusual transaction structures such as sub-sale relief, assignment of contracts, or partitioning arrangements.
HMRC also uses data analysis to identify patterns: returns where the effective SDLT rate is significantly lower than expected for the property type and purchase price, or where the same adviser is filing a high volume of claims in a specific relief category.
We review the HMRC enquiry letter and the original SDLT return to understand exactly what HMRC is questioning and why. We assess the strength of the position that was filed: whether the treatment was correct, whether it was supportable but arguable, or whether there may be an error that needs addressing.
We prepare a structured response to HMRC that addresses the specific points raised, provides the requested information, and presents the supporting analysis in a clear and professional format. Where the original position is correct, we defend it with evidence. Where there is an error, we quantify the exposure and advise on the most appropriate way to resolve it, including the penalty position.
Once instructed and authorised, we can manage correspondence with HMRC on your behalf. You remain responsible for your tax affairs and for the accuracy of the information supplied. We push for resolution within a reasonable timeframe and keep you informed at every stage.
Do not ignore the letter or its response deadline. Tell us promptly if a deadline is approaching so we can discuss whether we can assist and whether an extension needs to be requested.
An accurate response matters. If you are unsure what HMRC is asking or believe an earlier response contains an error, seek advice promptly so the position can be addressed.
Do not provide more information than specifically requested without first understanding the implications. This is not about withholding — it is about responding accurately and proportionately to what HMRC has asked.
Send us the letter along with a copy of the original SDLT return. We will review both, advise on the position, and prepare the response.
Request help with an SDLT enquiry or call 02477 45 5333. Include the response deadline and a brief outline of the issue in your initial enquiry. We will explain how to provide the supporting documents and confirm the scope of any engagement.
For related transaction advice, see our mixed-use SDLT and company and SPV SDLT services.
Send us the HMRC enquiry letter and your original SDLT return (or instruct your solicitor to provide it to us if they filed it).
We review the return and assess the basis of HMRC's enquiry. We advise you on the strength of the position and the likely range of outcomes.
We prepare and submit a formal response to HMRC with supporting documentation and analysis.
We manage all subsequent correspondence, including any follow-up requests from HMRC. If a meeting with HMRC is required, we attend on your behalf.
Tell us what you need help with. Our team will contact you to agree a suitable time to discuss your property accountancy or tax enquiry.
