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HMRC internal manual

Stamp Duty Land Tax Manual

Reliefs: Right to buy transactions, shared ownership leases etc: Shared ownership leases: treatment where market value election not made: staircasing transactions FA03/SCH9/PARA4A

In the absence of a market value election, stamp duty land tax is charged on the grant of a shared ownership lease on the normal lease basis - that is, on the premium paid for the grant of the lease and the net present value of the rent payable under the lease - see SDLTM10020.


  • the lease meets all the conditions at SDLTM27020 and SDLTM27030 or SDLTM27050 and
  • under the lease the lessee or lessees have the right to make further payments (“staircase”) in order to

    • acquire an additional interest calculated by reference to the market value of the dwelling and expressed as a percentage of the dwelling or its value and
    • reduce the rent payable under the lease,

any such acquisition is exempt from charge if, immediately afterwards, the total share of the dwelling held by the lessee or lessees does not exceed 80% Transactions whereby the lessee or lessees staircase above 80%, or staircase to 100% so acquiring the freehold reversion or full leasehold interest are chargeable to stamp duty land tax