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HMRC internal manual

Stamp Duty Land Tax Manual

From
HM Revenue & Customs
Updated
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Reliefs: Alternative property finance

Land sold to financial institution and re-sold to individual: General overviewFA03/S73

Where a financial institution purchases a property and re-sells it to an individual,the individual borrows some or all of the purchase price from the financial institutionand grants a mortgage to the financial institution over that property.

As two land transactions take place under these arrangements, the combined effect of thereliefs is to bring the stamp duty land tax payable on the purchase using thesearrangements in line with that payable on a purchase financed with a conventional mortgageproduct.

The second transaction, the transfer from the financial institution to the individual,carries full relief from stamp duty land tax.

Relief is not available if the individual

  • enters into the arrangements, or holds the lease or sublease, as a trustee and any beneficiary of the trust is not an individual
  • enters into the arrangements, or holds the lease or sublease, as partner and any of the other partners is not an individual