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HMRC internal manual

Stamp Duty Land Tax Manual

From
HM Revenue & Customs
Updated
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Introduction to pre-completion transactions

The stamp duty land tax (SDLT) rules for pre-completion transactions are at FA03/S45 and FA03/SCH2A. They are effective for pre-completion transactions entered into on or 17 July 2013 (subject to certain transitional rules).

The starting point for a pre-completion transaction is that there must be a contract for a land transaction within FA03/S44: a contract that is to be completed by a conveyance. Before that ‘original contract’ is substantially performed or completed, the purchaser under that contract may enter into a further agreement as a result of which another person is entitled to call for the conveyance of all or part of the subject-matter of the original contract. Such an agreement is a pre-completion transaction.

In the context of a pre-completion transaction, the purchaser under the original contract is sometimes called ‘the transferor’ and the ultimate purchaser ‘the transferee’.

The following pages of guidance explain the various provisions about pre-completion transactions (SDLTM21520-SDLTM21580) and then give some examples (SDLTM21590-SDLTM21700) of how they work in practice.