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.