Simon Howley considers the rules applying to multiple transactions that are treated as linked transactions for stamp duty land tax purposes.
The purpose of the stamp duty land tax (SDLT) provisions on linked transactions is to prevent purchasers from artificially splitting land transactions to reduce the SDLT liability.
Linked transactions are treated as a single transaction so that the applicable rates of SDLT are determined by the total consideration and the nature of the total land. The effect of transactions being linked is simply that more SDLT may be payable than would have been due had the transactions not been linked.
Recognising when transactions are linked can sometimes be difficult, withâ¯HM Revenue & Customsâ¯(HMRC) having little sympathy for the difficulty. HMRC has repeatedly emphasised that, as SDLT is a self-assessed tax, taxpayers and their advisers must consider all the facts that they
