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HMRC internal manual

Stamp Duty Land Tax Manual

Procedure: Completion following Substantial Performance of agreement for lease

If an agreement for the grant of a new lease was substantially performed (notional transaction), a further return will be due on actual completion. In these circumstances the grant is treated as a completely separate transaction (although linked to the notional transaction), overlap relief will be available. As a result, the further return will be a new SDLT1 sent to:-

BT Stamp Duty Land Tax

HM Revenue and Customs


and not a letter. However, if the NPV is nil because of the overlap relief, no notification is required and no action need be taken. Please note that application of overlap relief cannot lead to a negative figure, so no refund will be available if the tax calculation on the grant of the lease is less than that paid on substantial performance.