Guidance

Practice guide 33: large scale applications and calculation of fees

Updated 31 January 2022

Applies to England and Wales

Please note that HM Land Registry’s practice guides are aimed primarily at solicitors and other conveyancers. They often deal with complex matters and use legal terms.

1. Introduction

This practice guide provides information and advice on how to prepare and lodge large-scale applications and how to calculate fees payable for such applications. Examples of types of applications covered, include:

• transfers of mortgage portfolios
• multiple sales of commercial properties from one company to another
• bulk acquisitions of titles to freehold reversions (ground rents)
• the voluntary first registration of a portfolio of unregistered properties or a large estate

Fees on applications affecting 20 or more land units are dealt with in more detail in How to calculate fees on large-scale applications.

The Bulk Applications Team deal with large-scale applications comprising a common deed or deeds affecting registered and/or unregistered land and which affects more than 50 wholly registered titles or any combination of registered titles and unregistered properties exceeding 50 in total.

2. Who to contact for advice

If your application is a large-scale application:

• use our contact form to contact the Bulk Application Team directly
• phone: 0300 006 0411 (general customer support)

They will then arrange for someone to phone you to explain the procedures involved.

The Bulk Application Team will provide technical advice on the best way of preparing and lodging your application.

If your application contains:

• a UK company or corporation with major national interests
• an overseas companies or other overseas organisations
• a formal approval of mortgage documentation, sought in the circumstances described in Seeking prior approval of any charge
• a document executed other than in accordance with section 36A of the Companies Act 1985 or section 74 of the Law of Property Act 1925

you should bring it to the attention of our staff when you contact us.

3. Voluntary first registration

If there are voluntary first registration applications affecting a large area of land or more than 20 individual voluntary first registrations, contact Customer Support:

• use our contact form
• phone: 0300 006 0411

You will be contacted by an HM Land Registry office to discuss the registration requirements and timescales and, where the project requires, to arrange for a visit to your office to discuss the project in more detail.

Note that it may be necessary to enter into an agreement with the registrar covering such matters as:

• the evidence required to identify the land clearly on the Ordnance Survey map
• the deeds and other documents relating to the title that will be lodged pursuant to rule 24(1) of the Land Registration Rules 2003
• the form in which these documents, or any of them, are to be lodged, including whether by way of originals or certified copies, and whether in hard-copy or electronic form

See the Chief Land Registrar’s Direction on large-scale voluntary applications for first registration.

4. The forms to use

The forms that you need to use depend on the nature of the transaction.

Where the land is wholly registered, use either:

• form TR4 – for a transfer of a portfolio of registered charges
• form TR5 – for a transfer of a portfolio of titles (whole or part)

When the transaction involves transfers of part and/or land which is not yet registered, use either:

• form TP2 – transfer of land (part) under power of sale by a registered chargee
• form TR5 – for a transfer of a portfolio of titles (whole or part)

Each transfer deed must be supported by application(s) relating only to titles affected by that deed. You may use one form AP1 to apply for the registration of the transfer of all affected registered titles.

The situation is different for unregistered property. You must use a separate form FR1 in respect of each unregistered property transferred by the deed to provide the appropriate certificate as to title investigation. A document list, form DL (in duplicate), must be provided with each form FR1. However, please note that an application to register a dispositionary lease out of a registered title must be made using form AP1 and not form FR1.

Continuation pages for any panel on the transfer forms must be on form CS. Free format continuation sheets are not permitted. However, you are allowed to expand existing panels on any form and, if your software allows this, you will not then need to use form CS.

Make sure the title numbers listed on form CS are in ascending, alphanumerical order.

See The documents that should be lodged with the application at the HM Land Registry office regarding retention of documents submitted with application forms.

5. Getting guidance about the transfer

Send a copy of the transfer, at draft stage, to the Bulk Application Team. We will point out any amendments that are needed to comply with the Land Registration Act 2002 and Land Registration Rules 2003 and to avoid requisitions when the transfer is lodged for registration.

We will also check the form of execution and advise you if supporting evidence, such as a power of attorney or board resolution, is required.

Any documents referred to in the transfer will need to be lodged if, in our judgement, the transfer cannot be fully interpreted without them.

If these documents contain commercially sensitive information, you should consider reframing the transfer to avoid referring to them. Deeds referred to on the register and any supporting documentation lodged with HM Land Registry are available to the public as of right.

Where the transfer contains an application for a restriction, you will need to consider the points set out in Restrictions.

6. Seeking prior approval of any charge

A charge for this purpose means a legal mortgage or charge over land. You should send a copy of the charge or draft charge for inspection. We will need to inspect the charge for:

• the charging clause
• any application for the noting of an obligation to make further advances
• validity of execution or proposed form of execution

If the charge contains an application for a restriction you will need to consider the points set out in Restrictions. Approvals of charges containing standard restrictions must be directed to Commercial Arrangements Section at HM Land Registry Head Office and not an HM Land Registry office – see Restrictions. For information about this, please see practice guide 30: approval of mortgage documentation.

7. Restrictions

Only standard forms of restriction (as set out in Schedule 4 to the Land Registration Rules 2003) are permitted in transfers, approved forms of charge and in clause LR13 in a prescribed clauses lease. If clause LR13 is not completed in such a lease, any application to register a restriction contained within the body of the lease will be ignored. All other forms of restriction in transfers, leases and approved forms of charge must be applied for using form RX1.

If the restriction is not a standard form of restriction, the registrar must be satisfied that the terms of the proposed restriction are reasonable and that applying the proposed restriction would be straightforward and not place an unreasonable burden on the registrar. If the restriction requires notice to be given to a person, requires a person’s consent or certificate or is a standard form restriction that refers to a named person, remember to include that person’s address for service.

Any approval for restrictions given for a charge forming part of an application are for that particular application only. The approval does not extend beyond the application in question. If it is the intention that a particular form of charge is to be used on subsequent applications, and:

• that charge will be in favour of the same lender
• its wording is constant

you should bring this to our attention when seeking approval of the application as it may be possible to apply to Commercial Arrangements Section at HM Land Registry Head Office for specific approval using form ACD.

8. Transfers of charges by local authorities

Where charges, registered or not, are transferred by a local authority, the consent of the borrowers must accompany the application to register the transfer. This is because, under section 7(3) of the Local Government Act 1986, a transfer of a charge by a local authority made without the consent of the proprietor of the land is void. Each consent must:

• be signed by all the proprietors of the land
• be dated no earlier than six months before the date of the transfer
• identify (where appropriate) the title against which the charge is registered
• be in the form prescribed by the Local Authorities (Disposal of Mortgages) Regulations 1986 (S.I. 1986/1028)

The transfer must also contain, in panel 9, a certificate by the vendor local authority confirming that the consent to the transfer given by the proprietor(s) of the land has not been withdrawn or ceased to have effect.

9. Change of name and/or change of address for service

Changes of name as the result of a statutory vesting or transfer of engagements are substantive applications that require completion by registration.

If the application is simply a request to change the name of a UK company registered under the Companies Acts, which has land holdings or registered charges in England or Wales and is already entered on the register, then you should lodge a certified copy of the appropriate certificate of incorporation of change of name to the Bulk Application Team, together with a list of the title numbers affected under cover of a completed form AP1.

Changes of name, vestings or mergers of oversea companies that have land holdings or registered charges in England or Wales should initially be referred to the Bulk Application Team by phone or in writing if preferred.

10. How we deal with your application

Where you have contacted HM Land Registry as detailed in Who to contact for advice, the appropriate team will process the application.

Where you have contacted the Bulk Application Team, they will either arrange for an HM Land Registry office to be nominated to deal with the application or to act as a controller for a group of HM Land Registry offices nominated to assist with the application. The Bulk Application Team will coordinate the processing of the application and provide you with written details of the steps you need to take, the timetable of lodgement and the method of calculating the fees.

You will be given a local contact name and their contact details. The contact will be responsible for processing the application and will be available to discuss any problems that may arise.

Once the application has been lodged at an HM Land Registry office they will assume the operational responsibility and it becomes subject to the normal registration procedures. Once the application has been lodged at the HM Land Registry office, the Bulk Application Team will no longer be involved.

11. How to lodge your application

If it is more convenient for you to lodge your application in a number of tranches, this can usually be arranged. The Bulk Application Team will consider any such request and advise on lodgement procedures.

Bundles of documents and boxes must not exceed 12kg in weight, as this is a safe weight for one person to lift. Each bundle should be numbered and should have a sheet attached listing the documents within the bundle/case. The boxes should also be numbered and a manifest provided to enable our staff to find documents easily.

Each deeds bundle relating to a first registration must include its own form FR1 and form DL.

12. Stamp Duty Land Tax and Land Transaction Tax

You will need to supply a land transaction return certificate with your application if appropriate. Where a transaction completed on or after 1 April 2018 relates to land falling in both England and Wales, you will need to supply separate return certificates in respect of Stamp Duty Land Tax and Land Transaction Tax.

We cannot register any land transaction without such a return or form unless the transaction is an exempt interest or is the subject of a statutory exemption. We will reject applications received without the relevant certification or a letter from the lodging conveyancer explaining why no certificate has been lodged.

13. Completion of HM Land Registry forms

13.1 Completion of form AP1

• Panel 1: complete as ‘Various Districts’
• Panel 2: complete as ‘See continuation sheet CS’. You should then prepare form CS listing all the title numbers in alphanumeric order
• Panel 4: complete as appropriate. If several transfers of part are involved, a further continuation sheet may be required as for panel 2. You must differentiate between the 2 continuation sheets
• Panels 5-8: complete as appropriate
• Panel 9: complete with the agreed address for service
• Panel 10: complete with the name and address for service of the proprietor of the charge(s), if any
• Panel 11: complete as appropriate
• Panels 12-15: complete as required, sign and date

13.2 Completion of form TR4

• Panel 1: this must be completed and the details under the three headings must be provided. If any property is not registered, enter ‘U’ in the title number column. The property description must include the road name and postal town and, where possible, the postcode. We must be able to identify the property from its postal address in cases where a mistake has been made in the title number. If we cannot identify the title, we may cancel the application against that property. If you have difficulty in completing this panel contact us in writing or you can raise it at any meeting that takes place
• Panels 2-8: complete as appropriate
• Panel 9: you may use this to insert any provisions or other matters as required
• Panel 10: ensure the method of execution follows the correct form for the transaction

Where authorised signatories or attorneys have executed on the transferor’s behalf, you should ensure that the signatures are witnessed and that you supply evidence of their authority to act.

13.3 Completion of form TR5

• Panel 1: the first three columns must be fully completed. You should state whether the whole or part of the title number is affected. The property address must be a full postal address (see the notes to panel 1 of the form TR4). The fourth column should be completed as appropriate
• Panels 2-6: complete as appropriate
• Panel 7: this panel must not be altered or expanded as it contains the statutory words of transfer
• Panels 8-10: complete as appropriate
• Panel 11: this panel is to be used for any additional elements relating to the transfer, such as, provisions, easements or restrictive covenants. Any continuation sheets must use form CS. You cannot add further words of execution to this panel. If the transaction is ‘by the direction’ of a third party, a simple statement to that effect may be incorporated. You cannot incorporate a subsale as this takes effect as a separate transfer and must be made on its own form
• Panel 12: complete as panel 10 of the form TR4 above

13.4 Completion of form FR1 and form DL

Each individual first registration application must be accompanied by a completed form FR1 in which all relevant panels must be completed, and a form DL (in duplicate) listing all the documents lodged which relate to that application.

A value must be stated in panel 4 of the form FR1, as it is required for the fees assessment. Where the property has been conveyed other than for full value, the fees will be assessed under the current Land Registration Fee Order on the unencumbered market value, see HM Land Registry: Registration Services fees.

13.5 Completion of a prescribed clauses lease

Clauses LR1 to LR12 must be completed as appropriate. Clauses LR13 and LR14 may be omitted.

14. The documents that should be lodged with the application

Note: Original documents are normally only required if your application is a first registration.

A conveyancer may, however, make an application for first registration on the basis of certified copy deeds and documents only. For information about this, see practice guide 1: first registrations – Applications lodged by conveyancers – acceptance of certified copy deeds.

If your application is not for a first registration, we will need only certified copies of deeds or documents you send to us with HM Land Registry applications. Once we have made a scanned copy of the documents you send to us, they will be destroyed. This applies to both originals and certified copies.

The application should contain:

• the application form (such as, AP1 or FR1), with clear instruction on who to return the documents to
• certified copies of the main disposition forms (such as TR4, TR5 and charge)
• if the application includes a transfer that is expressed to be subject to leases, or other incumbrances that are not referred to on the register, the original or certified copies of those documents (except where the documents are only referred to in an indemnity covenant)
• any necessary evidence of change of name
• evidence of execution of the deed: for example, Power of Attorney or Board Resolution, where the deed has not been executed using one of the acceptable methods as set out in practice guide 8: execution of deeds
• the appropriate fee
• completed form RX1 where a restriction is required that is either non-standard or is not applied for in an approved document (rule 92 of the Land Registration Rules 2003)
• completed form(s) DI where required and a certificate copy of any lease if revealed in panel 4 of the form. Practice guide 15: overriding interests and their disclosure contains information about what should be disclosed
• the land transaction return certificate, if appropriate
• the application should be marked for the attention of the contact name (which will be provided by the Bulk Application Team for large-scale application) at the relevant HM Land Registry office

Note 1: Applicants will appreciate that these types of applications can be very complex matters to register. Please do everything possible to ensure that applications are complete in every detail and are free of obvious clerical errors.

Note 2: Where the large-scale application is set up by the Bulk Application Team, and specific instructions issued, you will be informed as to what supporting documentation is to be lodged with your application as certain aspects will be covered in the initial stages prior to lodgement. This will reduce the amount of information that will be required by the processing office and reduce the incidence of additional requisitions.

We will do everything possible to complete these applications with the minimum of delay. However, we may reject applications on receipt if they are lodged in an unacceptable condition, or cancel applications if requisitions are not complied with.

Information on our rejection policy is contained in practice guide 49: return and rejection of applications for registration and on our requisition and cancellation policy in practice guide 50: requisition and cancellation procedures.

Where the application involves first registrations, you will need to lodge a certified true copy of the transfer document and/or conveyance for each title as well as the original document. The certified copy must include a coloured copy of the plan of land sought to be registered. A certified copy of any charge will also be required. If the property is leasehold, a full certified copy of the lease must also be supplied.

Please ensure that where the original deed plans contain colour references that all copy plans included copy deeds lodged are similarly coloured.

15. The evidence of title that needs to be produced on a first registration

Note: What follows is subject to the terms of any agreement with the registrar pursuant to the Direction on large scale voluntary applications for first registration (see Voluntary first registration).

In addition to the documents referred to in The documents that should be lodged with the application, you will need to supply documentary evidence of title for each property subject to first registration.

Our requirements are the same for large-scale application as for a single registration application. This means that you should follow the normal conveyancing practice of title investigation for each property.

A form FR1 and a form DL (in duplicate) must be prepared for each property and placed with its bundle of deeds. You must also supply land charge searches for each property. To avoid requisitions, those searches must contain a certificate stating entries which affect the land. If the search results are bulky and apply to a large number of properties in your application, you should raise the point with us, as we may be able to make a special arrangement to accept certified extracts for each property.

Often the documentation or the application form needs a plan. We need to be able to accurately identify the land to be registered where the title deeds either refer to an old plan that cannot be reconciled with the current Ordnance Survey detail or the deeds only refer to the property by way of an insufficient description. Any plan should be prepared to the following guidelines.

• It should be drawn true to scale and have a north point
• It must be at a scale that enables us to accurately identify the extent being registered. Preferred scales are 1/1250 or 1/500 for urban or sub-urban properties and 1/2500 for rural properties such as farms or large tracts of land. Scales using the imperial system of measurement (such as, 16 feet to 1 inch) are not acceptable
• It must show sufficient detail to enable the position and precise extent of the property to be related to the current Ordnance Survey map (such as, roads and road junctions and other land marks) and it must not mask any existing detail shown on the plan
• The property that you wish to register must be clearly identified by edging or colouring (red edging is conventionally used)
• Multiple parcels of a property (such as, house, parking space, dustbin space) must be identified separately by suitable plan markings
• Different floor levels must be identified on the plan and in the text of the deed
• Buildings, and any access drives and pathways that form plot boundaries, must be shown in their correct positions
• Intricate boundaries should be shown by using a larger scale or inset plan
• Undefined boundaries (where there is no physical feature) must be drawn accurately and located by reference to metric measurements on the plan if necessary
• Any measurements on the plan must be shown using metric units
• Any dimensions shown on the plan should correspond, as far as possible, to the scaled measurements
• It should not be marked, or referred to, as being for identification only
• Statements of disclaimer intended to comply with the Property Misdescriptions Act 1991 are not acceptable for registration purposes. They are also inappropriate to any pre-completion services such as searches of the index map or official searches of part of a registered title

You must avoid using ‘copy protected’ plans for your document. These are plans that have an inbuilt device that prevents photocopies being taken. Such plans are not acceptable as this prevents the scanning of the plan.

Where you intend to use computer-generated plans for your deeds, you should refer a draft example to us before you finalise the deed, preferably with the draft transfer. We will then confirm their acceptability or give further guidance.

Where there is a conflict between the latest Ordnance Survey detail and the detail shown on older deed plans on which you may have based an application, it may be necessary to refer the deed back to you for more information or clarification.

16. Applications to register legal charges on registered and unregistered land

If the charge includes a first legal charge over unregistered land, which is to be protected by the deposit of title deeds, then an application for first registration of that land is compulsory.

17. How to calculate fees on large-scale applications

17.1 How the fee is calculated

The fee is assessed under the fee order at the date of the application.

Where an application affects 20 or more land units the fee is payable under Article 6 of the fee order unless a greater fee would be payable under Scale 1 (for first registrations, transfers on sale of land and registration of leases out of registered titles), or Scale 2 (for charges, transfers of charges and transfers of land not on sale).

A ‘land unit’ means:

(i) the land registered under a single title number other than, in the case of an application to register a charge, any estate under any title number which is included in a primary application within the meaning of article 5(2), or

(ii) on a first registration application, a separate area of land not adjoining any other unregistered land affected by the same application.

Where an application for the registration of a transfer of whole, a charge of whole or a transfer of charge is delivered by electronic means, the scale fee payable will be reduced by 55%. However, large-scale applications, under article 6, are not subject to the 55% reduction.

The fee under Article 6 is the sum of:

• £10 for each of the first 500 land units comprised in an application, and
• £5 for each additional land unit over 500 units

There is a maximum Article 6 fee of £40,000 (£30,000 for voluntary applications) which applies to first registration applications. There is no cap on registered land. The tables with examples A, B and C later in Examples illustrate this formula.

Where the application is a large-scale voluntary first registration, the fee order makes provision under Article 2(5) for a 25% reduction in fees. The examples below relate solely to compulsory registrations.

17.2 Application of Article 6

To decide whether you should assess the fee under Article 6, ask yourself, in relation to each application that you intend to make:

• does this application relate to 20 or more registered land units?
• does this application relate to 20 or more unregistered land units?

If the answer to both questions is ‘yes’, then you will need to consider Article 6 (see examples A, B and C in Examples).

If the answer to both questions is ‘no’, then Article 6 is not relevant, and you should calculate the fee under Scale 1 or 2 in the normal way (see example D in Examples).

If you answered ‘yes’ to only one of the questions, then you need to consider Article 6 for that application. You will pay a scale fee on the application for which your answer was ‘no’ (see example E in Examples).

17.3 Examples

Example A

A transfer on sale lodged on paper comprises 60 unregistered and 36 registered land units. This transfer gives rise to 2 separate applications, one on form FR1 for first registration of the unregistered land and the other on form AP1 for registration of the transfer of the registered titles. You will need to pay a separate fee for each application, based on the land units affected by the application. The fee payable with the form FR1 will be at least £600 under Article 6 and that payable with the form AP1 will be at least £360. But you will also need to calculate both fees in the ordinary way under Scale 1, based on the amount of the purchase price attributable to the unregistered and registered units respectively. If the Scale 1 fee is greater than the Article 6 fee then you should pay the Scale 1 fee. The table below shows how you would make this calculation.

Land units and type of application	Value £	Fee band	Fee £	Highest fee £
First registrations of 60 units (FR1)	750,000	Scale 1	655 (or 495 if voluntary)	655
		Article 6: 60 land units @ £10 per unit	600
Transfer of 36 registered titles (AP1)	5,000,000	Scale 1	1,105	1,105
		Article 6: 36 land units @ £10 per unit	360
			Total payable	1,760

Example B

A transfer on sale comprises 550 unregistered and 9,550 registered land units. As in example A, this transfer gives rise to 2 separate applications, and you will need to pay a separate fee for each application, based on the land units affected by the application. The table below shows how you would calculate the fee in this case.

Land units and type of application	Value £	Fee band	Fee £	Highest fee £
First registrations of 550 units (FR1)	more than 1,000,000	Scale 1	1,105 (or 830 if voluntary)	5,250
		Article 6: 500 land units @ £10 per unit and 50 land units @ £5 per unit	5,250
Transfer of whole of 9,550 registered titles (AP1)	more than 1,000,000	Scale 1 - lodged electronically Scale 1 - lodged on paper	500 1,105	45,250
		Article 6: 500 land units @ £10 per unit and 9,050 land units @ £5 per unit	45,250
			Total payable	50,500

Example C

A single lease comprises land out of registered titles and unregistered land. For the part granted out of registered titles, there are more than 20 registered titles and, for the part granted out of unregistered land, more than 20 land units.

The fee payable for the registration of a lease is normally assessed under Article 2 of the Fee Order and this covers both a lease granted out of registered land (a registrable lease) and also a lease where the land is unregistered (an application for first registration). However, Article 2(2) is subject to Article 6 so, in this example, Article 6 applies.

There are also 2 separate applications: one for registration of the lease out of the registered titles and a second application for first registration and so, each application should be considered individually.

Example D

A transfer on sale comprises 31 land units, 17 being unregistered and 14 registered. This transfer also gives rise to 2 separate applications, one for first registration of the unregistered units and the other for registration of the transfer of the registered titles. You will need to pay a separate fee for each application. But in this case Article 6 does not apply because each application comprises less than 20 units. You will, therefore, calculate the 2 fees in the ordinary way under Scale 1, based on the purchase price attributable to the unregistered and registered units respectively. Where an application for the registration of a transfer of whole is delivered by electronic means, the scale fee payable will be reduced by 55%.

Example E

A transaction consists of 32 first registration and 16 registered title applications. The fees for the registered land units are assessed separately from the fees for unregistered land units. In this case, the first registration application may qualify for Article 6 (32 land units) but a scale fee will apply for the registered titles (16 land units). Where an application for the registration of a transfer of whole is delivered by electronic means, the scale fee payable will be reduced by 55%. Please note, that the fee under Article 6 is not reduced by 55% see How the fee is calculated.

Example F

Company A owns 15 registered titles and company B owns 12. Company C agrees to lend £4,000,000 to A and B on the security of charges over the 27 titles. Even though they are contained in one document, both secure the same loan and both are in favour of C, there will be 2 separate charges – one by A of 15 titles and one by B of 12 titles. The charge will result in 2 separate applications, one to register the charge by A and the other to register that given by B. Although the ‘deal’ comprised 27 titles, each application affects less than 20. So, in this case, a Scale 2 fee is payable on each application and Article 6 cannot apply. Where an application for the registration of a charge of whole is delivered by electronic means, the scale fee payable will be reduced by 55%.

18. Transfers of charges

The fee for registration of a transfer of charge, or of several charges, by the same transferor to the same transferee, is normally assessed under Scale 2 of the fee order on the value of the consideration for the transfer. If there is no consideration, the fee is assessed on the amount secured by the charge(s). If, however, the charge or charges transferred relate to 20 or more registered titles then the fees are assessed under Scale 2 or Article 6 of the fee order, whichever is the greater. Where an application for the registration of a charge of whole or a transfer of charge is delivered by electronic means, the scale fee payable will be reduced by 55%. Please note that the fee under Article 6 is not reduced by 55% see How the fee is calculated.

On applications where there are 19 or fewer titles involved the fee will be assessed under a scale fee for the registered titles and for the first registrations. Please note, that fees are assessed separately for first registrations and registered titles.

19. Large-scale pre-completion applications (such as official copies and official searches)

There is no special service available for large-scale pre-completion applications. The quickest and cheapest way is to use our online services. If you do not use our online services you can lodge applications by sending the relevant application by post or DX to our standard address.

20. Things to remember

When preparing a large scale application, remember that:

• you must count registered land units separately from unregistered units, as you will need to make 2 separate applications – one for registration of dealing with registered land and the other for first registration of the unregistered units (the fees are assessed separately, see examples A, B and C)
• to qualify for Article 6, the application must relate to a single document, such as a transfer or transfer of charge(s), which affects all the titles – a series of separate transfers would not meet this criterion
• you cannot aggregate land units that are in different legal ownership, even if they are being transferred or charged to a common purchaser or chargee, see example F
• you cannot aggregate land units that are transferred or charged by one legal owner to several separate purchasers or chargees

We only provide factual information and impartial advice about our procedures. Read more about the advice we give.