Linked leases and stamp duty: HMRC’s contents page
Linked leases at a glance
HMRC’s source page is an index to its guidance on linked leases. The legislation can treat successive linked leases as one lease for SDLT.
- The contents page does not provide a calculation itself.
- The leases, premises and wider arrangement need checking together.
- HMRC guidance does not replace the legislation.
Scroll down for the full analysis.
Read the original guidance here:
Linked leases and stamp duty: HMRC’s contents page
This HMRC page is a contents list, not a stamp duty calculation tool. It points you to guidance on linked leases, which can matter where several leases are part of one wider deal.
What this rule is about
You may sometimes need to consider more than one lease together for SDLT. That can change the result. The key issue is not simply whether there are two documents.
The law treats a series of leases as one lease where they cover the same, or nearly the same, premises and are linked.
What the official source says
HMRC’s page lists the parts of its internal manual that deal with linked leases. It does not set out the detailed answer on this page.
- an overview of linked leases
- calculating successive leases
- an example of successive leases
- calculating leases in a single scheme
- an example of a single scheme
- pre-implementation material for a single scheme
- an example of that earlier material
What this means in practice
Do not calculate each lease in isolation just because each has its own agreement. First ask whether the leases form part of the same plan.
- Keep every lease, renewal and side letter together.
- Check whether the premises overlap or are substantially the same.
- Check whether the same parties, or connected parties, are involved.
How to analyse it
Start with the facts, then apply the law. A linked transaction forms part of a single scheme, arrangement or series between the same parties, or connected people.
- List each lease and its start date.
- Compare the premises shown on the plans.
- Check whether the leases follow one another.
- Look for one commercial arrangement behind them.
Example
Sam takes a lease of an office and later takes another lease of substantially the same office. If both leases are part of one arrangement, the law may treat the series as one lease for SDLT. Sam cannot treat the later lease as automatically separate just because he signed it later.
Why this can be difficult in practice
This is the part people can miss: labels such as “renewal” or “new lease” do not settle the point. The plans, timing and wider deal matter.
- Premises may partly overlap rather than match exactly.
- A later lease may be planned from the start.
- Connected companies can matter as much as named parties.
Key takeaways
- This HMRC page is a guide to further manual pages.
- Several leases may need to be considered together.
- Check the full arrangement, not only one lease document.
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 108 — when land transactions are linked
- FA 2003 Schedule 17A para 5 — how successive linked leases are treated
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 leases concern the same or substantially the same premises can depend on the facts.
- Whether arrangements form one scheme, arrangement or series may need careful review of the documents and parties involved.
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.
- All lease documents and any replacement or renewal leases
- Plans showing the premises covered by each lease
- Dates, lease lengths and rent details
- Documents showing how the leases and parties are connected
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 Linked leases and stamp duty: HMRC’s contents page [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 108 - when land transactions are linked https://www.legislation.gov.uk/ukpga/2003/14/section/108/2025-11-17 - FA 2003 Schedule 17A para 5 - how successive linked leases are treated https://www.legislation.gov.uk/ukpga/2003/14/schedule/17A/paragraph/5/2025-11-17 Guidance page from HMRC on this topic (guidance, not law): https://www.gov.uk/hmrc-internal-manuals/stamp-duty-land-tax-manual/sdltm17032 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 leases concern the same or substantially the same premises can depend on the facts. - Whether arrangements form one scheme, arrangement or series may need careful review of the documents and parties involved. 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 1 September 2026
Useful article? You may find it helpful to read the original guidance here: Linked leases and stamp duty: HMRC’s contents page
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