Who are V and P in the stamp duty anti-avoidance rule?
V and P: the starting point
Section 75A first asks who gave up the land interest and who received it. HMRC calls those people V and P.
- Look at the whole arrangement
- Do not rely only on document labels
- Remember that other section 75A conditions still apply
Scroll down for the full analysis.
Read the original guidance here:
Who are V and P in the stamp duty anti-avoidance rule?
For this stamp duty anti-avoidance rule, start with two questions: who gave up the land interest, and who ultimately received it? The law calls those people V and P. Getting their identities wrong can alter the whole SDLT analysis.
What this rule is about
Section 75A addresses arrangements in which several linked steps transfer land, and its first condition identifies V, who parts with the interest, and P, who receives it.
That is only the starting point. It does not, by itself, mean the rule applies.
What the official source says
HMRC’s manual says V and P must be identified by considering the whole set of linked steps, called the scheme transactions. It describes this as an objective exercise.
After setting out all the related steps, HMRC says the real effect of the arrangements should determine who V and P are. The labels or order selected in the paperwork should not determine the result.
- V is the person who gives up a chargeable interest: an interest in land that SDLT can cover.
- P is another person who gets that same interest.
- P can instead get an interest which comes from V’s interest.
- HMRC says it has no choice about who V and P are once the facts are known.
What this means in practice
Do not stop with the contract that appears to sell the property. A chain may include companies, leases, transfers, or other steps.
To do this properly, put every contract, transfer, grant, payment and other step in time order, then show what each person held at the beginning and after the arrangement had run its course.
Record each person’s final holding.
- Make a list of every party involved.
- Set out what each party held before the steps began.
- Record what each party received at the end.
- Keep the contracts and a clear timeline together.
How to analyse it
Work through the facts in order. This separates the first condition from the rest of the anti-avoidance test. If more than one person might be P after all the linked steps have been considered, the HMRC manual directs readers to separate guidance on that issue.
Use that guidance.
- Identify the land interest that V gave up.
- Identify the person who gave it up.
- Trace each linked step, not just the final transfer.
- Identify who received the same interest or one that came from it.
- Only then consider the other conditions in section 75A.
Example
As an illustration, Nia owns a freehold. A planned series of steps ends with Omar holding a lease that comes from Nia’s freehold.
For the first condition, Nia may be V and Omar may be P, but that conclusion alone does not establish that section 75A applies because its other conditions must still be met.
The remaining conditions matter.
Why this can be difficult in practice
Paperwork can make a simple result appear complex. A lease, a new company, or a later step may obscure the link between the original land interest and the one P receives.
Facts matter. The source does not provide a full answer for every structure.
- A different legal interest may still come from the original one.
- More than one person may seem capable of being P.
- Calling a step separate does not end the wider factual review.
Key takeaways
- Start by finding who gave up the land interest and who got it.
- Look across all linked steps, not one document in isolation.
- Finding V and P is necessary, but it is not the whole test.
Technical analysis
For advisers, and for anyone who wants to check the law behind this page. You do not need this section to understand the guidance above.
Legislation
- FA 2003 section 75A — identifying V and P in linked land arrangements; scheme transactions connected with the land transfer; comparing stamp duty across the arrangement
- FA 2003 section 48 — interests in land that SDLT can cover
Official guidance
The pages below are HMRC’s guidance. Guidance is not law. It sets out how HMRC reads the legislation, and it is not binding on you, on a tribunal or on a court. Where guidance and the legislation differ, the legislation wins. HMRC can also change or withdraw guidance, and it may not cover your facts.
Where this is not settled
- The result can depend on the full facts and documents for every step in the arrangement.
- This HMRC page does not explain how to choose P where more than one person could potentially be P.
Evidence you would need
This kind of case is decided on the facts of the individual property. These are the records that usually settle it, and the ones an adviser would ask you for.
- Contracts, transfers, leases and other documents for each step
- A timeline showing who held each land interest before and after the arrangement
- Details of every party involved in the linked steps
Explore this with an AI
Readers often want to test their own situation. Copy the prompt below into ChatGPT, Claude or Gemini. It hands the model the actual legislation for this page rather than letting it answer from memory, and tells it to be explicit about what is uncertain. What comes back is information, not advice – check it against the links above.
I am researching UK Stamp Duty Land Tax (SDLT), which applies in England and Northern Ireland. MY QUESTION Who are V and P in the stamp duty anti-avoidance rule? [Replace this with your own situation: what you are buying, the price, the dates, who the buyer is, and what you plan to do with the property.] THE LAW THIS TURNS ON - FA 2003 section 75A - identifying V and P in linked land arrangements https://www.legislation.gov.uk/ukpga/2003/14/section/75A/2025-11-17 - FA 2003 section 75A - scheme transactions connected with the land transfer https://www.legislation.gov.uk/ukpga/2003/14/section/75A/2025-11-17 - FA 2003 section 75A - comparing stamp duty across the arrangement https://www.legislation.gov.uk/ukpga/2003/14/section/75A/2025-11-17 - FA 2003 section 48 - interests in land that SDLT can cover https://www.legislation.gov.uk/ukpga/2003/14/section/48/2025-11-17 Guidance page from HMRC on this topic (guidance, not law): https://www.gov.uk/hmrc-internal-manuals/stamp-duty-land-tax-manual/sdltm09130 HOW I WANT YOU TO ANSWER 1. Work from the legislation above. Read it before answering. Guidance from HMRC is its view of the law, not the law, and does not bind a tribunal or a court. 2. Tell me what the rule actually requires, in plain English. 3. Tell me which facts decide the answer, and which facts would change it. 4. Tell me what evidence I would need to support the position. 5. Be explicit about anything unsettled or fact-sensitive. Do not guess. 6. Your training data has a cutoff and SDLT rates and reliefs change at fiscal events. Say so if you are not sure the law is current. POINTS ALREADY KNOWN TO BE UNCERTAIN ON THIS TOPIC - The result can depend on the full facts and documents for every step in the arrangement. - This HMRC page does not explain how to choose P where more than one person could potentially be P. Do not give me a conclusion you cannot support from the provisions above.
Legislation links show Finance Act 2003 as it stood on 2025-11-17. The law may have changed since, and the rules that apply are those in force on the date of your transaction. The official guidance this page is based on is here.
This page was last updated on 31 August 2026
Useful article? You may find it helpful to read the original guidance here: Who are V and P in the stamp duty anti-avoidance rule?
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