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HMRC internal manual

Stamp Duty Land Tax Manual

Calculation of stamp duty land tax: Rent: Variable or uncertain rent: Royal payments, extraction of mineral rights etc.

For SDLT purposes in Scotland, royalty payments represent payments for the use of, or for a right over, land and are treated in the same way as rent.

Since the amount payable is likely to be unascertained at the effective date and also to be variable, the provisions of FA03/S51(1) and FA03/S51(2) apply by virtue of FA03/SCH17A/PARA7, that is, a reasonable estimate of the amount payable should be included for the first five years in calculating the net present value.

See SDLTM18525 for the approach when the end of the fifth year is reached.