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HMRC internal manual

Stamp Duty Land Tax Manual

HM Revenue & Customs
, see all updates

Commencement and transitional provisions

Provisions for variations and contracts on or after 10 July 2003 FA03/SCH19/PARA4(3)

There are special provisions for contracts for Stamp Duty Land Tax transactions madebefore implementation date. Such a contract might be

  • a contract made on or before 10 July 2003 which


  • was not substantially performed on or before 10 July 2003 but has been varied after that date, or
  • where the contracting purchaser has sub-sold or transferred his rights after that date, or


  • a contract made after 10 July 2003 but before implementation date

The substantial performance of such a contract before implementation date isdisregarded. This means that a charge to Stamp Duty Land Tax can arise, if at all, only oncompletion by virtue of


The following examples all concern transactions where a contract was entered into on 1 August 2003