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HMRC internal manual

Stamp Duty Land Tax Manual

HM Revenue & Customs
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Calculation of stamp duty land tax: Rent: Rate thresholds: Example 6

A lease on a shop is granted for consideration consisting only of rent. The net present value (NPV) of the rent payable is £125,350. This lease is wholly non-residential.

As part of the same deal, the tenant also enters into a lease with the landlord to rent the flat above the shop. The NPV of this lease is £15,650. This lease is wholly residential.

These leases are linked transactions as they are between the same landlord and tenant and taken out at the same time as part of an arrangement. The relevant rental values are therefore aggregated for the purposes of applying the relevant stamp duty land tax (SDLT)threshold: £125,350 + £15,650 = £141,000.

Where a transaction includes a lease or leases which are of mixed use (residential and non- residential), or a series of transactions combines residential and non-residential leases as here, the non-residential threshold applies.

As the aggregate relevant rental value (£141,000) does not exceed the non-residential threshold of £150,000, the 0% rate applies to the whole consideration and no SDLT is dueon the linked transactions

For guidance on the notification requirements for cases where no SDLT is due, refer to SDLTM12010.