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HMRC internal manual

Stamp Duty Land Tax Manual

Term of a lease: Missives to enter into minute of variation to extend the term of a lease

If the landlord and tenant conclude missives for the entering into of a minute of variation, such prior contract would not be treated as being substantially performed by reason of the tenant being in possession of the let property - as such possession is attributable to the existing, not the deemed new lease. Therefore the effective date is not the date of conclusion of the prior contract, but is the date of execution of the minute of variation in implement of that contract assuming the minute of variation is executed before the expiry of the old lease. If it is executed after the expiry of the old lease, the effective date would be the day after the expiry of the old lease.