Example of SDLT Calculation for Variable Rent with Five-Year Reviews

SDLT and Archived HMRC Guidance on Five-Year Rent Reviews

This archived HMRC manual page does not explain how SDLT applies to a lease with a five-year rent review. It only says that the worked example has been moved to another manual page, so the archived page should be treated as a signpost rather than current guidance.

• SDLT on leases can apply to rent as well as any premium, which can be more complex where rent is variable or uncertain.
• A five-year rent review may mean the future rent is not known at the effective date of the transaction.
• The archived page contains no substantive example or detailed guidance and simply directs readers to the replacement page, SDLT 13165.
• You should not rely on the archived reference alone; the current manual page must be checked for HMRC’s example.
• The correct SDLT treatment still depends on the legislation and the actual lease terms, including how the rent review clause works.
• Older notes and precedents may cite outdated manual numbers, so it is important to confirm that you are using the current HMRC guidance.

Scroll down for the full analysis.

SDLT and five-year rent reviews: why this archived HMRC example no longer appears here

This page concerns an archived HMRC manual entry about how Stamp Duty Land Tax is calculated where lease rent is variable or uncertain and the lease has a five-year rent review. The archived page itself does not set out the example. Instead, it simply says the example has been moved to another manual page. The practical point is that this page has no substantive guidance on its own, and the relevant example must be read in the replacement location.

What this rule is about

For SDLT on leases, tax is not charged only on any premium. It can also be charged by reference to the rent payable under the lease. That becomes more complicated where the rent is not fixed from the outset, or where it may change later under a review clause. A five-year rent review is one common situation in which the rent may be uncertain at the effective date of the transaction.

The legal issue is how SDLT should be calculated when the future rent cannot be stated as a single fixed amount at the start. HMRC’s manual material on variable or uncertain rent is intended to explain how those cases are treated.

What the official source says

The source provided here does not contain the example itself. It states only that the page is archived and that the example has been moved to “SDLT 13165”.

So, taken on its own, this source establishes only two points:

• this manual page should no longer be relied on as the current location of HMRC’s example; and
• the relevant example now appears elsewhere in the SDLT manual.

What this means in practice

If you are trying to understand HMRC’s worked example for a lease with a five-year rent review, this archived page will not help beyond redirecting you. You need to find the replacement manual page and read the example there.

More broadly, the existence of this archived entry is a reminder that manual references can change over time. If a conveyancer, taxpayer or adviser is checking HMRC guidance, it is important to use the current manual location rather than an archived page, especially where the issue is technical and example-driven.

This matters because SDLT on lease rent can turn on detailed assumptions in the example, such as:

• whether the future rent is fixed, variable or uncertain;
• when the review takes effect;
• whether the review clause sets a formula or leaves the amount unknown at the outset; and
• how the rent is treated for SDLT purposes at filing stage and, where relevant, later.

None of those details are given on this archived page, so they cannot safely be inferred from it.

How to analyse it

When you come across an archived SDLT manual page like this, a sensible approach is:

• first, identify whether the page contains any current substantive guidance or only a redirect;
• second, locate the replacement page referred to by HMRC;
• third, check whether the replacement material is explaining legislation, HMRC practice, or merely giving an illustration;
• fourth, read the example alongside the underlying lease terms, especially the rent review machinery;
• fifth, avoid treating the heading alone as the rule, because the tax result depends on the detailed facts and the statutory framework for lease rent.

In other words, this archived page is only a signpost. It is not a complete statement of the SDLT treatment of five-year rent reviews.

Example

Illustration: a reader finds a citation to “SDLTM13175” in an older note about lease SDLT. They open the page expecting a worked example on variable or uncertain rent. Instead, the page says the example has moved to “SDLT 13165”. The correct next step is not to rely on the archived page, but to read the replacement example and then consider how its facts compare with the actual lease being reviewed.

Why this can be difficult in practice

Manual pages are often cited in precedents, older articles and internal notes. When HMRC reorganises the manual, the old page number may still circulate long after the content has moved. That creates a risk that readers think they have found the relevant guidance when in fact they have only found an archive notice.

There is also a second difficulty. Even where the replacement example is found, examples in HMRC manuals are aids to understanding. They do not replace the legislation. In technical lease cases, especially where rent review clauses are unusual, the real question is how the statutory SDLT rules apply to the actual wording of the lease.

Key takeaways

• This archived page does not contain the substantive example; it only says the example has moved.
• For current HMRC guidance on this point, the replacement manual page must be consulted.
• In lease SDLT cases involving rent reviews, the detailed lease terms and the legislation remain central.

This page was last updated on 24 March 2026

Useful article? You may find it helpful to read the original guidance here: Example of SDLT Calculation for Variable Rent with Five-Year Reviews

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