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HMRC internal manual

Stamp Duty Land Tax Manual

Application - Pension Funds and linked transactions

Purchases by pension funds are subject to the provisions of section 108 Finance Act 2003. Where a fund purchases more than one property, the question of linkage should be addressed. If the transactions are part of a single scheme or arrangement or a part of a series of transactions between the same vendor and purchaser or, in either case, persons connected with them, then they will be regarded as linked. Tax is due on each transaction at the rate applicable to the total of the chargeable considerations passing for all those transactions involved.


Fund A agrees with individual B to purchase 3 parcels of land for £150,000 each. These purchases are regarded as linked. SDLT is due on each parcel at the rate applicable to the total consideration passing, £450,000.

One SDLT1 covering the three properties, or three separate SDLT1’s, each showing the transaction to be linked and the total consideration for all three shown, should be lodged.