Scope: What is chargeable: Contract and conveyance: General FA03/S44
In the vast majority of cases Stamp Duty Land Tax (SDLT) will arise on completion.
However a charge to SDLT will arise where a contract governing a land transaction is substantially performed before it is formally completed.
Whether or not a contract has been substantially performed is a question of fact.
SDLTM07700+ provides further guidance on the question of when substantial performance takes place.