Q&As

My client is purchasing a large development in tranches. Can my client claim multiple dwellings relief on some of the development and apply the commercial rates of stamp duty land tax to other parts of the development or must the same rate apply for the entire development as each tranche will be linked with the other tranches?

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Produced in partnership with Charles Goddard of Rosetta Tax
Published on: 21 February 2018
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Stamp duty land tax (SDLT) applies to chargeable land transactions. A land transaction is an acquisition of a chargeable interest (sections 42–43 of the Finance Act 2003 (FA 2003)).

Transactions are ‘linked’ for the purposes of the SDLT if they form part of a single series of transactions between the same vendor and purchaser or, in either case, persons connected with them (FA 2003, s 108). However, it is clear that just because transactions are linked, they are not treated as the same transaction. FA 2003, s 108(2) specifies that ‘Where there are two or more linked transactions with the same effective date, the purchaser may make a single land transaction return as if all of those transactions that are notifiable

Charles Goddard
Charles Goddard

Rosetta Tax

Charles is a solicitor at Rosetta Tax Limited, which specialises in corporate tax advice to businesses and professional services firms. He has a broad range of tax advisory expertise, having acted for a variety of UK-based and international financial institutions and listed companies. He has particular expertise in the real estate and finance sectors, with a strong focus on the taxation of insolvency and restructuring transactions.

Charles was for six years until 2012 a tax partner at Berwin Leighton Paisner LLP. Prior to joining BLP, he spent eight years at Slaughter and May as a trainee and associate in their Tax group. He is recommended by both Chambers and Partners and Legal 500.

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