When are property transaction steps connected for SDLT?
Connected steps under section 75A
HMRC says a transaction step may form part of an SDLT scheme if it helps bring about the route from the original owner to the final buyer. A sequence alone is not enough.
- Look at all agreements, transfers, payments and rights.
- Check whether steps were necessary or commercially dependent.
- Keep evidence of any separate commercial purpose.
Scroll down for the full analysis.
Read the original guidance here:
When are property transaction steps connected for SDLT?
A chain of property deals does not automatically create an SDLT scheme. But a step can count when it helps bring about the sale from the original owner to the final buyer. That can matter because section 75A may replace the chain with an assumed direct sale for stamp duty land tax purposes.
What this rule is about
Section 75A is an anti-avoidance rule. It can apply where an owner gives up a taxable interest in land and someone else ends up with it, or with an interest created from it.
This page asks a narrower question: which steps belong in that arrangement? Section 75A calls them “scheme transactions”. The answer can change the SDLT bill.
A taxable interest in land can include ownership, a lease, or certain rights over land. That is why the rule can matter beyond a simple house sale.
What the official source says
HMRC’s manual says that a transaction connects with the original sale and final purchase when it affects the transfer, forms part of the setting in which the buyer gets the land, or affects the SDLT due.
This is HMRC’s view of the statutory words. It is not a separate rule of law.
- A step can be connected when it helps transfer the land interest from the original owner to the final buyer.
- The wider setting in which the buyer obtains that interest can connect a step to the arrangement.
- A step can be connected when it affects the SDLT payable on the overall arrangement.
- A step is not connected simply because it comes before or after another step.
- HMRC says a step is likely to be connected when the result could not happen without it.
- In HMRC’s view, commercially interdependent steps are also likely to form part of the scheme.
What this means in practice
Do not stop at the document that puts the property into your name. A lease grant, an agreement not to exercise a right, a payment arrangement, or another non-land step may be relevant.
The key point is purpose and effect. Did the step play a real part in getting the property from the original owner to the final buyer, or was it separate?
- Map the whole arrangement, not only the final transfer deed.
- Check whether another step relied on completion of one step.
- Compare the SDLT across the steps with the result of a direct sale.
- Keep records that explain a step with its own commercial purpose.
How to analyse it
Start with the land interest and the people involved. Then work through the events in their real order. Labels such as “separate deal” do not settle the point.
- Who was the original owner of the land interest?
- Who ultimately obtained that interest, or an interest created from it?
- What agreements, payments, rights and transfers formed part of the route between them?
- Could the final result have happened without each particular step?
- Were the steps planned together or commercially dependent on each other?
- How close were the steps in time and in their practical effect?
- Why did each step happen, and what do the documents say about that reason?
- Did the arrangement reduce the combined SDLT compared with the assumed direct sale?
Example
Amir owns a freehold. A company first takes a lease from Amir, then grants a further lease to Beth, who ends up with the property rights she wanted. The lease steps may be connected if they were the planned route by which Beth obtained an interest derived from Amir’s freehold.
Changing one fact can matter. If the company took its lease for a separate business reason and Beth’s later deal was not planned or needed at that time, the connection may be harder to show. The paperwork and timing would matter.
Why this can be difficult in practice
People often assume that a sequence is enough. HMRC’s manual says it is not. Equally, putting separate documents in place does not necessarily make the steps separate for section 75A.
This is a fact-heavy question. The law uses broad words, and HMRC says its listed factors are not exhaustive.
- A step can be connected even if it is not itself a land transfer.
- A step after the buyer gets the land can still fall within the statutory meaning of transaction.
- Commercial dependence may point towards a single arrangement, but it is not the only factor.
- An independent business reason may be relevant, yet it does not by itself end the enquiry.
- Emails, board papers, contracts and payment records may show whether steps were planned together.
Key takeaways
- A sequence of property deals is not automatically an SDLT scheme.
- The real question is whether a step helped produce the route from original owner to final buyer.
- HMRC’s view is useful, but section 75A is the law that must be applied.
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 — anti-avoidance rule for connected land transaction schemes
- FA 2003 section 48 — what counts as a taxable interest in land
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 legislation does not define the precise boundary of ‘involved in connection with’. A particular step may be disputed where it has an independent commercial purpose.
- The supplied statutory text is current only to 17 November 2025. The SDLT position for a transaction after that date needs checking against current legislation.
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.
- A timeline showing each agreement, transfer, payment and completion date
- Documents showing why each step was included
- Details of links between the people and businesses involved
- Contracts and records showing whether steps depended on each other
- A comparison of SDLT across the steps and on the statutory assumed direct transaction
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 When are property transaction steps connected for SDLT? [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 - anti-avoidance rule for connected land transaction schemes https://www.legislation.gov.uk/ukpga/2003/14/section/75A/2025-11-17 - FA 2003 section 48 - what counts as a taxable interest in land 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/sdltm09190 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 legislation does not define the precise boundary of ‘involved in connection with’. A particular step may be disputed where it has an independent commercial purpose. - The supplied statutory text is current only to 17 November 2025. The SDLT position for a transaction after that date needs checking against current legislation. 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: When are property transaction steps connected for SDLT?
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