Stamp Duty Land Tax: mobile home was not a fixture and outside of scope
Tax
Stamp Duty Land Tax: mobile home was not a fixture and outside of scope
Is a mobile home a chattel and, therefore, outside of scope for the purposes of Stamp Duty Land Tax (SDLT)? Unsurprisingly, the answer is – ‘it depends’; but a recent decision is helpful in considering how the rules should apply in practice.
This is an interesting case that considered the not uncommon dichotomy in property and tax laws, namely whether an asset is deemed a chattel, or a fixture and therefore part of the land. If the asset is valuable, the outcome could be significant for the taxpayer.
It was in the context of Multiple Dwellings Relief (MDR is no longer available) that this case arose. However, the decision remains important because fixtures are subject to SDLT, while chattels are not.
What’s the background ?
Until its abolition in June 2024, a taxpayer was able to claim MDR on the purchase of more than one dwelling where a transaction or linked transactions included freehold/leasehold interests in more than one dwelling.
In Lambourne v HMRC [2026] UKFTT 00997, a couple purchased a house in East Sussex, and surrounding land on which there was a mobile home (also referred by the parties as an annex and caravan). They paid £1,010,000 plus £850 for chattels.
They claimed MDR. To benefit from MDR the mobile home had to be a fixture on the land. HMRC concluded that it was not a fixture – and issued a closure notice with a demand for £16,750.
Chattel
At issue on appeal was whether or not the mobile home formed part of the property’s land under Sch 6B para 2(5) and s48(1) Finance Act 2003. If so, it was a chargeable interest for SDLT purposes.
The FTT found as a matter of fact that the mobile home was “clearly self-contained” and not intended to form part of the land. Further, its purpose was not to permanently and substantially improve the land as a whole. The common sense conclusion was that it was a separate habitable unit and, therefore, a chattel and MDR did not apply.
However, the outcome meant it was not in any case chargeable to SDLT as it was not a fixture. As the original purchase price for the property and land had included payment for the mobile home, its value (to be agreed between the parties) was to be deducted from the chargeable consideration.
The final SDLT account could then be finalised.
Key takeaway
The decision it helpful for property purchasers and their advisers when determining the extent to which the land and property they purchase is chargeable to SLDT – particularly when the land includes separate units.
Often, this will be determined on a case-by-case basis and expert advice will usually be essential. For support from experienced tax specialists, please contact the team at NGM Tax.
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