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HMRC internal manual

Stamp Duty Land Tax Manual

Miscellaneous provisions: Lease assignations: treated as a new lease: Example 1

* A Ltd grants its subsidiary, B Ltd, a lease for a term of 25 years and B Ltd claims group relief on the grant
* after one year B Ltd assigns this lease to C Ltd, an unconnected third party

As the lease benefited from a relief at the previous transaction, (the grant by A Ltd to B Ltd), the assignation is treated as the grant of a lease for 24 years, this being the remainder of the original term. This transaction is treated as the grant of a new lease by B Ltd to C Ltd for notification purposes.

C Ltd would have to file a land transaction return and pay stamp duty land tax on the net present value of the remaining rent as for a normal grant and on any capital sum paid to B Ltd for the assignation.