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HMRC internal manual

Stamp Duty Land Tax Manual

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

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.