If, on completing the renewal of a stamp duty land tax lease, the parties agree a new, higher rent is payable from an earlier date, should the additional rent be chargeable as premium or rent? Does the answer alter depending on whether the term of the new lease is expressed to commence on the date the new higher rent becomes payable, or only on completion of the new lease?

Sean is a partner at Blick Rothenberg. For five years, he was head of stamp taxes at KPMG UK, finalist in the 2016 Taxation Awards for Best Big Four Tax Group. He has almost 20 years' experience advising, amongst others, developers, investors, occupiers, funds and banks on stamp taxes in connection with real estate transactions, group reorganisations, corporate reconstructions, demergers and placings. He is a barrister by training, a Fellow of the Chartered Institute of Taxation and council member of the Stamp Taxes Practitioners Group. Since 2007 he has been the editor of Sergeant & Sims on Stamp Taxes arguably the most comprehensive, up-to-date and authoritative guide to UK stamp taxes available. He was the Tax Writer of the Year in the 2017 Taxation Awards having ''demonstrated real in-depth expertise in analysing complex legislation'. He has contributed to the development of government policy, tax authority practice and statutes on stamp taxes, and is regularly consulted by tax authorities and government departments. He speaks and writes regularly on UK stamp taxes.