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HMRC internal manual

Stamp Duty Land Tax Manual

Reliefs: Disadvantaged areas relief

Mixed-use property FA03/SCH6/PARA6

Where only part of the land being transferred is residential property, as defined by FA03/S116, the consideration must be apportioned on a just and reasonable basis between the residential and non-residential elements.

The £150,000 limit for relief is then applied separately to the residential element of the transaction.

The just and reasonable test is necessarily subjective and each case will be considered on its merits.

Apportionment might be on the basis of the percentage areas quoted in planning applications, where appropriate, or alternatively of floor space relating to the respective uses. Other methods of apportionment will be considered as part of a claim.

All relevant documentation should be retained in support of the apportionment stated in the land transaction return.