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HMRC internal manual

Stamp Duty Land Tax Manual

Scope: When is Stamp Duty Land Tax (SDLT) chargeable: Contracts and substantial performance: What is substantial performance FA03/S44(5)

A contract is substantially performed when

  • the purchaser takes possession of the whole, or substantially the whole, of the subject matter of the contract. See SDLTM07900 
  • a substantial amount of the consideration is paid or provided. See SDLTM07950 

In every case whether the contract has been substantially performed or not will be a question of fact.