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HMRC internal manual

Stamp Duty Land Tax Manual

HM Revenue & Customs
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Example 6 , Series of subsales


This is an example of a series of subsales.

  • A enters into a sale and purchase agreement with B for some land with a consideration of £1 million. B pays A a deposit of £100,000.
  • B enters into a subsale agreement with C for £1 million, with C paying a deposit of £100,000.
  • C enters into a subsale agreement with D for £1.1 million, with D paying deposit of £200,000 to C.
  • The contracts are completed together. On completion, D pays C £900,000, C pays B £900,000, and B pays A £900,000.


B and C are chargeable on £1 million according to the normal rules in section 44. They can claim relief. D is chargeable on £1.1 million (see example 2 (SDLTM21600)).