54. Apportionment of purchase price.

The sale of chattels, including chattels which although attached to the land have not become fixtures, does not attract stamp duty land tax (SDLT)1 unless included in the conveyance. The value of chattels which have been included in the purchase price of the land may therefore be deducted from the total purchase price the remainder of which will be subject to SDLT. Only the fair value of the chattels may be deducted from the purchase price for this purpose2. Any over-valuation of the price of the chattels is a fraud on Her Majesty's Revenue and Customs which may render