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HMRC internal manual

Stamp Duty Land Tax Manual

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:

Transitional provisions - reduction of higher rate threshold from £2 million to £500,000 FA14/S111


The £2 million threshold is retained for transactions where a contract was entered into and substantially performed before 20 March 2014, or in any other case where a contract was entered into before that date unless

  • there is any variation of the contract, or assignment (or, in Scotland, assignation) of rights under the contract, on or after 20 March 2014,
  • the transaction is effected in consequence of the exercise on or after that date of any option, right of pre-emption or similar right, or
  • on or after that date there is an assignment (assignation), sub-sale or other transaction relating to the whole or part of the subject-matter of the contract, as a result of which a person other than the purchaser under the contract becomes entitled to call for a conveyance.


A deemed land transaction under FA03/SCH15/PARA17(2)/17A(4) (transfer of a partnership interest or withdrawal of money from the partnership following an acquisition by the partnership) remains subject to the £2 million threshold if the effective date of the acquisition by the partnership was before 20 March 2014.