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HMRC internal manual

Stamp Duty Land Tax Manual

HM Revenue & Customs
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Relief for transfers involving multiple dwellings: "off plan" transactions FA03/SCH6B/PARA7(5)-(6)


  • there is a contract to purchase a building, or part of a building, which is to be constructed or adapted under the contract for use as a dwelling or dwellings,
  • the contract is substantially performed before construction of the building, or part of the building, concerned has commenced and
  • the effective date of the transaction is deemed to be the date of substantial performance by virtue of FA03/S44/44A/45/45A or FA03/SCH17A/PARA12A or 19(3)

then, for the purposes of the relief, the main subject-matter of the transaction will be taken to consist of or include an interest in a dwelling.

For this purpose a contract includes any agreement including, in Scotland, missives of let not constituting a lease.