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HMRC internal manual

Stamp Duty Land Tax Manual

Miscellaneous Provisions: Linked leases: Single scheme: Pre-implementation

A lease which falls within the scope of stamp duty land tax (SDLT) may be linked to a previous lease that was executed prior to 1 December 2003 and so within the stamp duty regime, but such pre-SDLT leases are specifically excluded from the successive linked leases legislation at FA03/SCH17A/PARA5 by FA03/SCH19/PARA7(4).

The linked leases legislation at FA03/SCH5/PARA2 therefore applies. In the case of pre-implementation leases, the leases are aggregated for the purposes of arriving at a total figure of net present value for applying SDLT rates and thresholds. However, the applicable rates and thresholds are those relevant to the SDLT lease and no tax under SDLT is applied to the earlier lease itself in respect of the proportion of chargeable consideration attributable to it.