Who is V under section 75A stamp duty rules?
In short
HMRC says V is normally the person who held the relevant land interest immediately before an arrangement began. The answer depends on the facts and the route by which P obtained the interest.
- Trace P’s interest backwards
- Check every planned transfer
- Do not treat HMRC guidance as law
Scroll down for the full analysis.
Read the original guidance here:
Who is V under section 75A stamp duty rules?
For this stamp duty rule, V is usually the person who held the land interest before the planned steps began, even where later transfers and documents make that position less obvious. Later paperwork can obscure that position.
That may sound like a small label. It can be a key part of working out how section 75A applies.
What this rule is about
Section 75A uses letters to identify people in an arrangement. P is the person who ends up with an interest in the land. V is the person who gives up the interest that P gets, or the earlier interest from which P’s interest comes.
What decides it? The real path of the land interest, not simply the names used in the paperwork.
What the official source says
HMRC’s manual says V can be the person who disposes of the chargeable interest, meaning the interest in land, obtained by P.
V can instead be the person who disposed of an earlier interest from which P’s interest is derived. That applies where the earlier interest is the relevant source of P’s interest.
- Look for the interest P ends up with.
- Identify who gave up that interest, if any.
- Also consider the earlier interest from which it came.
- HMRC says V will normally hold the interest immediately before the arrangement begins.
What this means in practice
Do not treat the last seller named in the documents as V where a chain of planned steps means that another person held the relevant interest at the start. That earlier holder may matter.
- Set out every step in date order.
- Match each step to the land interest involved.
- Keep documents showing who held it before the steps began.
How to analyse it
Start with what P received. Then trace that interest backwards through the arrangement.
Several companies, trustees or transfers may be involved. At this stage, people can get the analysis wrong because the relevant interest may not follow the most obvious document trail.
Check it carefully.
- What exact interest did P obtain?
- Who disposed of it to P?
- Did it come from an earlier interest?
- Who held that earlier interest immediately beforehand?
Example
Leila holds a freehold interest before a planned series of transfers. Omar ends up with an interest that comes from Leila’s interest.
HMRC’s manual indicates that Leila will normally be V. This remains so even if another person appears between them in the documents and the intervening person is named in the transfer paperwork.
The full facts still matter.
Why this can be difficult in practice
Where arrangements contain several linked transfers and different interests in the same land, identifying the relevant interest may require consideration of the whole sequence rather than one step alone. One step may mislead.
A label in one contract does not settle the point. HMRC’s manual itself says the answer depends on the facts.
- A later holder may not be V.
- An earlier interest may be the important one.
- The documents and timing may point in different directions.
Key takeaways
- V is identified by tracing the relevant land interest.
- The starting holder will normally be V in HMRC’s view.
- Complex arrangements need a full timeline and documents.
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 in a section 75A arrangement
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 source does not explain exactly when P’s interest is derived from an earlier interest in a complex chain of transactions.
- The correct person to identify as V can depend on the documents and the order of the arrangement’s steps.
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.
- Documents showing who held each interest before the arrangement began.
- Contracts, transfers and completion records for every step.
- A clear timeline showing how P obtained the interest.
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 is V under section 75A stamp duty rules? [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 in a section 75A arrangement https://www.legislation.gov.uk/ukpga/2003/14/section/75A/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/sdltm09140 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 source does not explain exactly when P's interest is derived from an earlier interest in a complex chain of transactions. - The correct person to identify as V can depend on the documents and the order of the arrangement's steps. 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 is V under section 75A stamp duty rules?
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