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HMRC internal manual

Stamp Duty Land Tax Manual

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HM Revenue & Customs
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Provisions for variations and contracts on or after 10th July 2003 FA03/SCH19/PARA4(3): Examples

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

Example 2

A contract is entered into on 1 August 2003 and substantially performed on 1 September 2003.

On 1 November 2003 the contracting purchaser sub-sells.

The contract is completed by conveyance to the ultimate purchaser on 1 January 2005.

There is no charge to Stamp Duty Land Tax on the contracting purchaser because under the sub-sale rule in SDLTM01060 completion by conveyance to the ultimate purchaser does not trigger a charge on the contracting purchaser.