Who is P under the section 75A stamp duty rule?
Who is P?
P is the person who receives V’s land right, or a right derived from it, as part of a land transaction.
- Trace the land right through every step
- A derived lease may identify P
- This is only one part of section 75A
Scroll down for the full analysis.
Read the original guidance here:
Who is P under the section 75A stamp duty rule?
Under this stamp duty anti-avoidance rule, P is usually the person who ends up with the land right first held by V. P can also receive a right that comes from V’s original right. That detail can matter when a property deal has several steps.
What this rule is about
Section 75A looks at certain arrangements involving land. It uses letters to identify the people involved. V is the person giving up a land right. P is the person receiving it, or a right that stems from it.
This is only the starting point. Naming P does not, by itself, mean the rule applies.
What the official source says
HMRC’s manual says that P can be identified in either of these ways when P acquires a chargeable interest, which means, in simple terms, a recognised right over land. That acquisition is a land transaction.
- P gets the same land right that V gives up.
- Or P gets a land right derived from V’s right.
- P’s receipt of that right must form part of a land transaction.
- The manual is HMRC’s view, not the law itself.
What this means in practice
When working out who P is, do not focus only on the person who received the freehold, because a later lease or another right created from the original right may be relevant. Follow the rights instead.
- Trace the land right from V to its final recipient.
- Check whether P received the original right or a right created from it.
- Read the contracts, transfers and leases together.
- Do not assume a label used in the paperwork settles the point.
How to analyse it
Start with the land and follow the rights through each transfer or creation, asking what V gave up and what P actually received as the arrangement unfolded. Keep that sequence clear.
- Identify V’s original land right.
- Identify each later right created or transferred.
- Identify the person who received the relevant final right.
- Check that their receipt was a land transaction.
- Then consider the other section 75A conditions separately.
Example
Amir owns a freehold. A deal results in Beth receiving a lease created out of that freehold. Beth may be P, even though she did not receive Amir’s freehold itself. Her lease may be a right derived from it. Whether section 75A applies still depends on the rest of the statutory test.
Why this can be difficult in practice
Where property arrangements use companies, leases and several agreements, the key question is not simply who paid whom, but which land right moved, or was created, and who ended up with it. That question identifies the issue.
- A lease may come from a freehold without being the same right.
- Several documents may form one wider arrangement.
- Finding P does not settle the stamp duty result.
Key takeaways
- P can receive V’s original land right or a derived right.
- P must acquire that right through a land transaction.
- The other section 75A conditions still need checking.
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 43 — defines a land transaction as acquiring a land right
- FA 2003 section 48 — defines chargeable interests in land
- FA 2003 section 75A — identifies V and P in linked land arrangements; requires connected transactions in the arrangement; compares stamp duty under the 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
- Whether a later right is derived from V’s original land right can depend on the documents and the full chain of transactions.
- This short HMRC page does not explain how to decide every difficult case.
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.
- The documents showing what land right V held and gave up
- The documents showing the land right P received
- The agreements and dates for each connected step
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 P under the section 75A stamp duty 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 43 - defines a land transaction as acquiring a land right https://www.legislation.gov.uk/ukpga/2003/14/section/43/2025-11-17 - FA 2003 section 48 - defines chargeable interests in land https://www.legislation.gov.uk/ukpga/2003/14/section/48/2025-11-17 - FA 2003 section 75A - identifies V and P in linked land arrangements https://www.legislation.gov.uk/ukpga/2003/14/section/75A/2025-11-17 - FA 2003 section 75A - requires connected transactions in the arrangement https://www.legislation.gov.uk/ukpga/2003/14/section/75A/2025-11-17 - FA 2003 section 75A - compares stamp duty under the 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/sdltm09150 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 - Whether a later right is derived from V's original land right can depend on the documents and the full chain of transactions. - This short HMRC page does not explain how to decide every difficult case. 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 P under the section 75A stamp duty rule?
Search Land Tax Advice with Google
