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HMRC internal manual

Stamp Duty Land Tax Manual

Scope: How much is chargeable: Just and reasonable apportionment FA03/SCH4/PARA4

Where a transaction involves the acquisition/disposal of various items, not all of which are chargeable interests in land, or where the transaction is part of a deal including other transactions then the consideration should be subject to a just and reasonable apportionment. Two common situations where an apportionment will be required are

  • a residential purchase where chattels, in Scotland, moveables, are purchased as well as land and buildings. See SDLTM04010 
  • the purchase of a business, or assets of a business

The apportionment agreed between vendor and purchaser, for whatever purposes, may not represent a just and reasonable apportionment.

The purchaser, who is solely responsible for the accuracy of the information contained in the land transaction return, is expected to reconsider this question before entering the consideration for the land transaction on the return.

Further guidance regarding the valuation of assets by Valuation Office Agency can be found at SDLTM80350+.