HMRC internal manual

Stamp Duty Land Tax Manual

Miscellaneous Provisions: Linked leases: Successive: Calculation

Transactions are defined (at FA03/S108) as ‘linked’ for the purposes of stamp duty land tax (SDLT) if they form:

  • a single scheme or arrangement, or
  • a series of transactions

between the same parties (or connected persons).

Where two or more leases are linked as a series (‘successive’ linked leases), the legislation at FA03/SCH17A/PARA5 treats the series as though it were a single lease and sets out the method of calculating SDLT.

Refer to SDLTM17035 for details of what constitutes successive linked leases.

SDLT is calculated under FA03/SCH17A/PARA5 as though the series of leases were one lease:

  • granted at the time the first lease in the series was granted
  • for a term equal to the aggregate of terms of all the leases in the series, and
  • in consideration of the rent payable under all of the leases in the series.