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HMRC internal manual

Stamp Duty Land Tax Manual

Relief for transfers involving multiple dwellings: Example 3

The freehold reversion of a block of 20 flats is purchased. A 999-year headlease over the whole block has been granted to a company controlled by the tenants, with ten flats let on 99-year leases and the rest on leases of 21 years or less.

The transfer of the reversion is not a relevant transaction for the purposes of the relief as all the dwellings are subject to the 999 year headlease (a lease of more than 21 years). No relief is due. (If the transfer had been of the headlease this would be a relevant transaction in respect of the ten flats subject to leases of 21 years or less.)