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HMRC internal manual

Stamp Duty Land Tax Manual

From
HM Revenue & Customs
Updated
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Scope: when is Stamp Duty Land Tax (SDLT) chargeable: higher rate charge for acquisitions of residential property by certain non-natural persons FA03/S55/SCH4A: alternative finance arrangements FA03/SCH4A/PARA6B

Similar special rules apply to alternative finance arrangements under Section 72A where the major interest in land acquired in the ‘first transaction’ under Section 72A(1)(a) includes a higher threshold interest.

For the purposes of establishing the amount of SDLT due, the transaction is to be considered as though the financial institution was not one of the purchasers under that transaction. Again, if the other person who is a party to the first transaction is a person who would be liable to the higher rate of SDLT, the 15 per cent rate will apply unless that person meets the conditions for one of the exclusions from the higher rate charge (for example, if the higher threshold interest is to be used in a property rental business).