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HMRC internal manual

Stamp Duty Land Tax Manual

HM Revenue & Customs
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Miscellaneous Provisions: Lease Assignments: Treated as new lease: Example 2


* A Ltd grants a lease to an unconnected company B Ltd
* B Ltd pays stamp duty land tax on the chargeable consideration of the new lease
* B Ltd subsequently assigns this lease to C Ltd

As the lease hasn’t been subject to a relief claim in respect of the previous transaction (the grant from A Ltd to B Ltd), the assignment from B Ltd to C Ltd is not treated as the grant of a new lease.

Any capital sum paid to B Ltd is chargeable to stamp duty land tax.