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HMRC internal manual

Stamp Duty Land Tax Manual

Miscellaneous provisions: Linked leases: Successive: Calculation

Transactions are defined (at S108 of Finance Act 2003) 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 Para 5 of Sch17A Finance Act 2003 treats the series as though it were a single lease and sets out the method of calculating SDLT.

See SDLTM17035 for details of what constitutes successive linked leases.

SDLT is calculated under Para 5 of Sch17A 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.