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HMRC internal manual

Stamp Duty Land Tax Manual

Application: Deemed market value: Example 1

Example 1

An individual, A, transfers freehold residential property to company B, for consideration of £170,000.

SDLT considerations are:

Is A connected to B in accordance with S1122CTA10?

If so, what is the market value of the property transferred?

If A is not connected to B the chargeable consideration will be the amount paid, £170,000 at the rate applicable for residential property at the effective date of the transaction.

If A is connected to B S53 applies and the chargeable consideration for the transaction may be the market value of the property at the effective date. If this were £275,000 this would be the chargeable amount, if however the market value were only £150,000 the chargeable consideration would be £170,000, chargeable at the appropriate rate.