Payment of stamp duty land tax (SDLT)1 is due within 30 days of the 'effective date' of the relevant land transaction2. The effective date will normally be the date of completion, but where a contract for the land transaction has been entered into the charge to tax arises when the contract has been substantially performed3 and in some circumstances this will give rise to a charge to tax before actual completion. A contract is substantially performed when the purchaser, or a person connected with the purchaser, takes possession of the whole, or substantially the whole, of the subject-matter of
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