87. Capital gains tax, VAT and stamp duty land tax.

Entering into an agreement for a lease may attract capital gains tax1 and may constitute a supply for the purposes of VAT2.

For the purposes of stamp duty land tax3, where an agreement for a lease is entered into, and the agreement is substantially performed without having been completed, the agreement is treated as if it were the grant of a lease in accordance with the agreement ('the notional lease'), beginning with the date of substantial performance and the effective date of the transaction is that date4. Where a person assigns his interest as lessee under an agreement for a